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US Tax Disputes

Keeping an eye on US tax controversy and litigation developments.

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US Tax Disputes

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Jeff Erney

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IRS to end Offshore Voluntary Disclosure Program in September

By Jeff Erney
  • IRS
  • IRS Administration
  • Litigation

Eleventh Circuit Holds that Taxpayer’s Affidavit Can Defeat Summary Judgment

By Jeff Erney
  • IRS
  • IRS Administration
  • Partnerships/TEFRA

Who Qualifies as a Partner under the New BBA Regulations

By Jeff Erney
  • General
  • IRS
  • IRS Administration
  • Partnerships/TEFRA

IRS Issues Final Regulations on BBA Partnership Audit Regime

By Jeff Erney
  • Estate and Gift Tax
  • General
  • Individual Taxation
  • IRS
  • IRS Administration
  • Legislation
  • State and Local Taxation

Update on Tax Reform

By Jeff Erney
  • General
  • Individual Taxation
  • IRS
  • IRS Administration
  • Legislation

Tax Reform is Here

By Jeff Erney
  • IRS
  • IRS Administration
  • Partnerships/TEFRA

Substantial Changes to Partnership Tax Audit Procedures will Severely Impact Partner Liability and Rights Before the IRS

By Jeff Erney
  • IRS
  • IRS Administration

IRS To Revise Guidance for In-Person Appeals Conferences

By Jeff Erney
  • Circular 230 and Ethical Issues
  • Estate and Gift Tax
  • IRS
  • Litigation

Tax Court Disallows a $33 Million Charitable Donation Deduction Because Taxpayer Did Not Sufficiently Fill Out Form

By Jeff Erney
  • IRS
  • IRS Administration
  • Litigation
  • Tax Crimes

Supreme Court Agrees to Review Sweeping Tax Obstruction of Justice Decision

By Jeff Erney
  • Partnerships/TEFRA

IRS Urges Partnerships to Amend Partnership Agreements To Address Expanded Role of Partnership Representatives

By Jeff Erney

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