The Presumption of Innocence Podcast: Episode 21 - Conservation Easement Donations: Tax Shelter or Charitable Contribution Deduction?
Jones Day Presents: Strategies for Dealing with IRS Appeals: When Exam Attends the Appeals Conference
Jones Day Presents: Strategies for Dealing with the IRS: Going to Court
Jones Day Presents: Strategies for Dealing with the IRS: The IRS Appeals Office
La Cour administrative d'appel de Paris rappelle à l'administration fiscale son obligation de motivation de la réponse aux observations du contribuable sous peine d'entacher la procédure d'irrégularité (CAA Paris, 13 février...more
An anonymous thinker, lost to history, is credited with having said that the unofficial motto of the IRS is, “We have what it takes to take what you have.” In some instances, the truth of the above statement is manifested in...more
We previously provided an overview of the time limits imposed on the Internal Revenue Service (IRS) for assessing federal tax. The general rule is that the IRS must assess tax within three years from the later of the due date...more
A recent US Tax Court Memorandum Opinion held that a settlement agreement embodied in Internal Revenue Service (IRS) Form 870-AD does not preclude the IRS from reopening an audit and issuing a notice of deficiency. In Howe...more
In This Issue: - Fifth Circuit Ruling in BMC Software, Inc. v. Comm’r. Is Good News for Taxpayers - When Is a Second Inspection Not a Second Inspection? - Captive Insurance Litigation: Key 2014 Cases ...more