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February 15, 2023
IRS Inquiries and Examinations, Generally – Sections 6201 and 7602. Generally, the IRS is authorized and required by 26 U.S.C. § 6201(a) "to make the inquiries, determinations, and assessments of all taxes"..
February 14, 2023
IRS Inquiries and Examinations, Generally – Sections 6201 and 7602. Generally, the IRS is authorized and required by 26 U.S.C. § 6201(a) “to make the inquiries, determinations, and...
January 25, 2023
They Are People, Not Aliens- Believe it or not, IRS Agents are normal people just like you. They brush their teeth, pack their kids’ lunches, and drink coffee before going to...
January 23, 2023
If you don’t file your taxes, IRS penalties can range from mildly annoying to truly horrific.
October 29, 2022
It is crucial to be strategic with information provided to various countries regarding tax issues. Telling one country one story and taking a different position in the United States could lead to some tax adjustments and even a referral to the IRS’s criminal tax division.
March 14, 2022
When a US Taxpayer is under audit or examination by the Internal Revenue Service, it can be a stressful and overwhelming experience. Quite frankly…
March 10, 2021
In Coffey v. Commr, 987 F.3d 808 (8th Cir. 2021), the U.S. Court of Appeals for the Eighth Circuit reversed and remanded the U.S. Tax Courts decision in Coffey v. Commr, 150 T.C. 60 (2018). The Eighth Circuit held that, for statute of limitation purposes, a federal income tax return had not been filed even if the IRS received and stamped as received certain tax return documents from the U.S. Virgin Islands Bureau of Internal Revenue. This Holland & Knight alert explores the decision and its p...
February 5, 2021
IR-2021-29, February 5, 2021 WASHINGTON – The Internal Revenue Service today named Heather C. Maloy to the position of director, Taxpayer First Act Office. She will report directly to the IRS Commissioner in her new role. The IRS continues work on the Taxpayer First Act, part of legislation passed in July 2019. The IRS delivered the Taxpayer First Act Report to Congress PDF earlier this year, providing a comprehensive set of recommendations that will reshape the taxpayer experience, enhance...