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September 18, 2023
Michael R. Stevenson is better known by his stage name of Tyga.
August 24, 2023
When it comes to international information reporting penalties, the Internal Revenue Service does not play fairly. That is because internationalโฆ
May 5, 2023
On April 3, 2023, the Tax Court in Farhy v. Commissioner rejected IRS efforts to impose penalties on a taxpayer's failure to file Form 5471. According to the Tax Court, these foreign...
April 26, 2023
The recent Tax Court decision in Farhy demonstrates that clever and novel arguments can carry the day in complex tax litigation matters. In that case, the taxpayer stipulated...
April 13, 2023
The recent Tax Court decision in Farhy demonstrates that clever and novel arguments can carry the day in complex tax litigation matters.  In that case, the taxpayer stipulated that he: ...
April 12, 2023
Pursuant to Section 6038(a), taxpayers who have certain interests in foreign corporations during the taxable year are required to file a Form 5471 with their tax return.
March 13, 2023
Summary: In this collection due process (CDP) case, Mehlek Dawveed sought review of the determination by the IRS to uphold a notice of Federal tax lien (NFTL) and a notice of intent to...
February 27, 2023
Summary: Since 1982, James William Avery (Avery) was a practicing lawyer, specializing in personal injury law as a solo practitioner primarily in Denver, Colorado for the period...
December 6, 2022
Last summer, the Supreme Court of the United States held that the 30-day time limit to file a Collection Due Process (CDP) petition is a non-jurisdictional deadline subject...