When is an Issue Tried by Consent?

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