Section 6751(b) Penalty Approval Circuit Split

Equitable Estoppel in Texas

The Defense of Accord and Satisfaction in Texas

The Defense of Unconscionability in Texas

Tips For Negotiating with the IRS

A Graev Matter: § 6751

The Accuracy-Related Penalty and the Reasonable Cause Defense

Litigating FBAR Penalties | The Burden of Proof and the Meaning of Willfulness

Litigating IRS Penalties

The Cheek Defense to Federal Tax Crimes