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
On June 12, 2025, the U.S. Supreme Court issued a significant decision in Commissioner of Internal Revenue v. Zuch, clarifying the jurisdictional boundaries of the U.S. Tax Court in Collection Due Process (CDP) appeals....more
In a recent case of first impression, the U.S. Tax Court has held that it does not have to rely solely upon the administrative record in determining whether the IRS erroneously certified a taxpayer as having a seriously...more
Earlier this year the IRS announced that, as part of its larger compliance efforts begun last fall under the Inflation Reduction Act, the agency’s stepped-up enforcement activity with respect to high wealth, high income...more
United States v. Firestone - In United States v. Firestone, the United States (Government or U.S.) sought to enforce a judgment against Defendant Omar Firestone (Omar) for outstanding tax liabilities related to the Estate of...more
In a rare unanimous opinion, the U.S. Supreme Court recently confirmed that existing law allows the IRS to probe your bank records, without ever notifying you. Under the applicable statute, the Court concluded the IRS is not...more
I was a youngster for the Woodstock Music and Art Fair commonly known as Woodstock took place in Bethel, NY between August 15-18, 1969. Frankly, I never knew anyone growing up in the Canal Zone that attended in person. The...more
Tax Litigation: The Week of June 6th, 2022, through June 10th, 2022 Musselwhite v. Commissioner, T.C. Memo. 2022-57 | June 8, 2022 | Ashford, J.| Dkt. No. 14380-16 Spencer v Commissioner, T.C. Memo. 2022-8 | June 7, 2022 |...more