Tomato, Toma-toe: IRS’s Imperfect Designation of “Immediate Supervisor” Deemed Insufficient to Overturn Penalties Under Code Section 6751(b)(1)
By Penalties, Section 6751, Tax Court
Jan 27, 2022
Willful FBAR Penalties and a District Court’s Authority to Remand IRS Willful Penalty Computations
By Cross-Border Tax Insights, FBAR, International Tax
Jan 26, 2022
The Tax Court in Brief – January 9 -15th 2022
By Tax Court, The-Tax-Court-in-Brief Insights
Jan 24, 2022
Market Value vs. Book Value | Proving Consequential Damages
By Business Litigation, Texas Supreme Court Insights
Jan 22, 2022
CDP Proceedings | Is the Time Limit in Section 6330(d)(1) a Jurisdictional Requirement for Tax Court Petitions?
By Collection Due Process (CDP), Tax Court
Jan 20, 2022
Criminal Tax Statutes of Limitations and Suspensions: 18 U.S.C. § 3292 and the Fifth Circuit’s Decision in Pursley
By Criminal, Tax Evasion, White-Collar Defense Insights
Jan 19, 2022
The Foreign Tax Credit
By Cross-Border Tax Insights, Foreign Tax Credit, International Tax
Jan 18, 2022
Implied-Revocation Doctrine Revived by Texas Supreme Court
By Business Litigation, Contracts, Texas Supreme Court Insights
Jan 17, 2022
And, Action! – Film Clearance Licenses, Antitrust, and the Burden of Proof
By Business Litigation, Texas Supreme Court Insights
Jan 15, 2022
Common Mistakes in Submitting an IRS Streamlined Filing Compliance Procedure Submission: And a Discussion of Professional Malpractice
By Streamlined Filing
Jan 14, 2022
IRS Summonses and the Collection of Unpaid Taxes
By Bankruptcy, IRS Collection, Summonses
Jan 13, 2022