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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: ...
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.
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...
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...
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...