Insights

I.R.C. § 7212 | Interfering with the Administration of Tax Laws

The IRS’s Bank Secrecy Act Program Has Minimal Impact on Compliance

Tax Evasion: Evading the Payment of Tax

The Willful Failure to Collect or Pay over Tax

Fixing a Terminated S Corp. Election

Tax Evasion: Attempting to Evade the Assessment of Taxes

The Crime of Tax Evasion

Fraudulent Tax Information

IRS Use of Big Data Leads to 400% Increase in Detection of Tax Fraud by Criminal Investigation Division

A Collection Due Process Hearing

The Attorney-Client and Work Product Privileges in the Tax Context

Tips For Negotiating with the IRS

International Tax Enforcement: The Joint Chiefs of Global Tax Enforcement

FBAR Penalty Update

A Graev Matter: § 6751

What You Need to Know About Federal Tax Liens and Levies

Representing Non-Filers

Conducting a Successful Interview with a New Client