Tax Litigation Insights

Estate Tax, Penalties, Tax Litigation Insights, tolling

Court Finds Reasonable Cause for Estate’s Late Form 706 Filing

By Jason B. Freeman Feb 09, 2020
Settlements, Tax Litigation Insights

The Taxability of Fee-Shifting Statutes: Wait, My Award is Taxable?

By Jason B. Freeman Feb 05, 2020
Audit, Tax Litigation Insights

The IRS Office Audit

By Freeman Law Mar 14, 2019
Attorney-Client Privilege, Privilege, Tax Litigation Insights, Work Product Privilege

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

By Jason B. Freeman Nov 14, 2018
Summonses, Tax Litigation Insights

The IRS is like the Soviet Hockey Team: Presley v. U.S.

By Freeman Law Sep 14, 2018
Tax Litigation Insights

The Most Litigated Tax Issues

By Jason B. Freeman Jul 22, 2018
Economic Substance, Tax Litigation Insights

What is “Economic Substance?”

By Freeman Law Apr 09, 2018
Cross-Border Tax Insights, International Tax, Tax Litigation Insights

Summoning Foreign Records: The Section 6038A Summons

By Freeman Law Sep 13, 2017
Defenses, Penalties, Tax Litigation Insights

The Accuracy-Related Penalty and the Reasonable Cause Defense

By Jason B. Freeman Mar 04, 2017
Bank Secrecy Act, Defenses, FBAR, Tax Litigation Insights, White-Collar Defense Insights, Willfulness

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

By Jason B. Freeman Dec 16, 2016
Tax Litigation Insights

The 10 Most Litigated Tax Issues of 2015

By Jason B. Freeman Sep 06, 2016