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May 29, 2024
Navigating tax controversies with the IRS demands a strategic approach and a deep understanding of the process.
April 25, 2024
The question raised in Mukhi was similar to that in Farhyโand the Tax Court wasnโt willing to deviate from that ruling.
April 19, 2024
In Mukhi v. Commissioner of Internal Revenue, a collection due process case, the U.S. Tax Court considered multiple constitutional challenges to civil penalties...
April 2, 2024
The doctrine of mootness applies to all Article III courts, and it applies throughout the course of the litigation. The Tax Court also applies the mootness doctrine.
April 2, 2024
U.S. citizens and residents who have received gifts (including bequests) exceeding certain thresholds from foreign persons must generally report such gifts to the IRS. Recipients...
March 28, 2024
U.S. citizens and residents who have received gifts (including bequests) exceeding certain thresholds from foreign persons must generally report such gifts to the IRS. Recipients of...
March 25, 2024
Robert Goulder considers whether a taxpayer-friendly outcome in Farhy would spark a general reformation of the IRS international information reporting penalties.
March 9, 2024
Our latest edition of Tax Breaks. A ruling on the Corporate Transparency Acts stirs things up, reporting for gifts and inheritances, tax filing season updates and more.
January 25, 2024
Dealing with the IRSs Automated Collection System (ACS) can be an overwhelming experience for individuals dealing with tax issues.
October 11, 2023
He's in a financial tailspin, and the IRS is another creditor.