Insights

Tomato, Toma-toe: IRS’s Imperfect Designation of “Immediate Supervisor” Deemed Insufficient to Overturn Penalties Under Code Section 6751(b)(1)

Willful FBAR Penalties and a District Court’s Authority to Remand IRS Willful Penalty Computations

Foreign Earned Income Exclusion

No Right to Intervene? | IRS Third-Party Summonses

The Tax Court in Brief – January 9 -15th 2022

“Money Had and Received” Claims Under Texas Law

Negligent Misrepresentation in Texas

Market Value vs. Book Value | Proving Consequential Damages

What Can the State of Texas Do to Collect State Taxes?

CDP Proceedings | Is the Time Limit in Section 6330(d)(1) a Jurisdictional Requirement for Tax Court Petitions?

Criminal Tax Statutes of Limitations and Suspensions: 18 U.S.C. § 3292 and the Fifth Circuit’s Decision in Pursley

The Foreign Tax Credit

Implied-Revocation Doctrine Revived by Texas Supreme Court

Donkeys and Taxes

And, Action! – Film Clearance Licenses, Antitrust, and the Burden of Proof

Common Mistakes in Submitting an IRS Streamlined Filing Compliance Procedure Submission: And a Discussion of Professional Malpractice

IRS Summonses and the Collection of Unpaid Taxes

IRS Criminal Investigation’s Top Ten Cases of 2021