NYU Tax Controversy Forum

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Jason B. Freeman

Jason B. Freeman

Managing Member

214.984.3410
Jason@FreemanLaw.com

Mr. Freeman is the founding member of Freeman Law, PLLC. He is a dual-credentialed attorney-CPA, author, law professor, and trial attorney.

Mr. Freeman has been named by Chambers & Partners as among the leading tax and litigation attorneys in the United States and to U.S. News and World Report’s Best Lawyers in America list. He is a former recipient of the American Bar Association’s “On the Rise – Top 40 Young Lawyers” in America award. Mr. Freeman was named the “Leading Tax Controversy Litigation Attorney of the Year” for the State of Texas for 2019 and 2020 by AI.

Mr. Freeman has been recognized multiple times by D Magazine, a D Magazine Partner service, as one of the Best Lawyers in Dallas, and as a Super Lawyer by Super Lawyers, a Thomson Reuters service. He has previously been recognized by Super Lawyers as a Top 100 Up-And-Coming Attorney in Texas.

Mr. Freeman currently serves as the chairman of the Texas Society of CPAs (TXCPA). He is a former chairman of the Dallas Society of CPAs (TXCPA-Dallas). Mr. Freeman also served multiple terms as the President of the North Texas chapter of the American Academy of Attorney-CPAs. He has been previously recognized as the Young CPA of the Year in the State of Texas (an award given to only one CPA in the state of Texas under 40).

For a while now, NYU has held an annual tax controversy forum.  Generally, it is held in-person in New York City.  Of course, this year, the COVID-19 pandemic sidelined the in-person event, but, thankfully, NYU decided to provide the forum free of charge online through webinars.  The forum provides tax professionals a valuable opportunity to hear from top-level government officials on IRS enforcement and collection activities.  This year, although via webinar, was no different.  Some of the more noteworthy discussions included:

IRS Collection Actions.  IRS officials discussed the IRS’ People First Initiative, which has delayed collection action against most taxpayers until July 15, 2020.  When asked about whether collection action would be stayed beyond July 15, 2020, an IRS official indicated this would be determined at a later date.  IRS officials also indicated that they had implemented new procedures for installment agreement requests.  Previously, it was standard procedure for the IRS to refer a case to a Revenue Officer (i.e., to the field) if there was a request for an installment agreement and the aggregate taxes at issue were in excess of $100,000.  Currently, the IRS has increased that amount to $250,000 in an attempt to help taxpayers more easily enter into installment agreements, potentially over the phone.  With respect to offers-in-compromise, the IRS acknowledged that many OICs had not been reviewed yet due to IRS office closures.  However, they indicated that their OIC offices in Brookhaven, New York and Memphis, Tennessee were beginning to slowly open back up again.  The IRS also indicated that they are not sending out failure-to-deposit notices for unpaid employment taxes like they have in the past but that they are currently reviewing whether they should do so after the second quarter of 2020.  The IRS cautioned that the new Forms 7200, Advanced Payment of Employer Credits Due to COVID-19, were being carefully reviewed and would be subject to scrutiny in the future.

 

State and Local Tax Services

Freeman Law works with tax clients across all industries, including manufacturing, services, technology, oil and gas, financial services, and real estate. State and local tax laws and rules are complex and vary from state to state. As states confront budgetary deficits due to declining tax revenues and increased government spending, tax authorities aggressively enforce state tax laws to recapture lost revenues. 

At Freeman Law, our experienced attorneys regularly guide our clients through complex state and local tax issues—issues that are frequently changing as states seek to keep pace with technology and the evolution of business. Staying ahead requires sophisticated legal counsel dedicated to understanding the complex state tax issues that confront businesses and individuals. Schedule a consultation or call (214) 984-3000 to discuss your local & state tax concerns and questions.