A strict two-year deadline to file a refund lawsuit is approaching for denied Employee Retention Credit (“ERC”) claims, and taxpayers facing recapture on previously issued ERC claims have limited windows to challenge Internal Revenue Service (“IRS”) collection efforts. Furthermore, IRS appeals backlogs mean taxpayers cannot rely on the administrative process to timely resolve their claims
G. Gordon Liddy, convicted of several criminal charges for his role in the Watergate scandal, made the statement that “obviously crime pays, or there’d be no crime.” John Maynard Keynes, economist and philosopher, further indicated that “the avoidance of taxes is the only intellectual pursuit that still carries any reward.” As we enter the fourth
It’s no secret that spouses, particularly in bad times, may hide things from one another. In fact, there are bodies of cases involving such marital behavior. However, we’ve gotten another recent reminder that such attempts can land you in hot water with the IRS, even if you were never out to hide anything from them
Artificial Intelligence continues to impact all industries as companies and individuals try and find the perfect balance between automation and sufficient oversight and monitoring. Tax reporting would appear, on its face, to be a prime candidate for the promises of efficiency achieved through AI’s streamlined review of large amounts of data and identification of potential
On Feb. 19, 2025, President Donald Trump issued Executive Order 14219, titled “Ensuring Lawful Governance and Implementing the President’s ‘Department of Government Efficiency’ Deregulatory Initiative.” The primary purpose of Executive Order 14219 is to direct federal agencies to review and rescind regulations that are deemed unconstitutional or that undermine national interests. The executive order
The Internal Revenue Service was aware of significant underreporting of cryptocurrency on tax returns and used one of its investigative tools (i.e., a John Doe summons) in 2016 to seek financial information on thousands of individuals, including James Harper. Harper sued in 2020, alleging unlawful access to his private financial information, and has been embroiled
The Internal Revenue Service (IRS) recently issued Private Letter Ruling (PLR) 202504006, addressing several important estate and gift tax questions related to the division of a marital trust and the subsequent disclaimer of a surviving spouse’s interest in a portion of the trust. This ruling provides valuable insights into the tax treatment of trust divisions
In 2024, the IRS ramped up its focus on partnerships, including several actions before President Trump took office. However, with a new Treasury Secretary Scott Bessent confirmed, new IRS Commissioner Billy Long named but not yet confirmed, federal funding cuts, a federal hiring freeze, and employee reductions at both IRS and the Department of Justice
Headlines and updates on sweeping changes to operations and staffing with regards to numerous federal agencies, and now implementing new tariffs, as we enter tax filing season may have people even more on edge than years prior at the sight of a letter from the IRS or any chatter about taxes in general. If the
An old German proverb states that “to change and to change for the better are two different things.” As 2024 ends, the legal and business communities who must navigate government scrutiny are seeing the signs of change in the regulatory landscape on the horizon. The pencils for redrawing the lines of government involvement in economic