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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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IRS Enforcement News Alert: Employee Retention Credit (“ERC”) Claims

By Gregory Rhodes, Michelle Levin, Mark A. Loyd, Kristin Martin Centeno, and Sidney Jackson
  • General
  • IRS

Navigating the Latest IRS Updates on Employee Retention Credit Claims

By Gregory Rhodes and Mark A. Loyd
  • General
  • IRS

IRS and Treasury Department wave white flag in battle over the Administrative Procedure Act notice and comment requirements: Submit comments on the proposed regulations regarding micro-captive insurance by June 12, 2023

By Gregory Rhodes, Ronald Levitt, and Kristin Martin Centeno
  • General
  • IRS

IRS Releases Notice 2023-30 With Guidance on Correcting Conservation Easement Deeds

By Ronald Levitt and Emily Ellis
  • General
  • IRS

Tax Implications of Chevron Challenge

By Michelle Levin
  • General
  • IRS

Wrzesinski v. US

By Michelle Levin and J.R. Davidson
  • General
  • IRS

The Future of FBAR After Bittner

By Gregory Rhodes, Michelle Levin, Ronald Levitt, Mark A. Loyd, and Bailey Roese
  • General
  • IRS

3M Opinion: The Tax Court’s Evolving View of the Administrative Procedure Act

By Michelle Levin and Logan Abernathy
  • General
  • IRS

Green Rock Rolls Over Notice 2017-10

By Michelle Levin, Ronald Levitt, and Sarah Green
  • General
  • IRS

11th Circuit Decision – Penalty Approval by Supervisor Allowed at Any Time Prior to Assessment

By Gregory Rhodes, Logan Abernathy, and Emily Ellis
  • General
  • IRS

Act Fast to Qualify for IRS Penalty Relief

By Mark A. Loyd, Bailey Roese, and Stephanie Bruns
  • IRS
  • IRS Examination Process

IRS to Begin Hundreds of High-Net-Worth Examinations in July

By Jeff Erney, Mark A. Loyd, Bailey Roese, and Brian Raftery

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