July 2018

New Compliance Campaigns by the IRS in 2018
Listen Regularly, the Internal Revenue Service focuses its attention on new areas that may need regulation and tax scrutiny from the federal government. Because of the IRS’s reputation, it’s easy to confuse related initial contacts with audits, but the IRS has a very specific approach when it comes to creating new tax regulatory schemes over previously unregulated …
Clock Ticking Down on the Offshore Voluntary Disclosure Program, Time Is Of The Essence
Listen Just when you thought it was safe to get back in the water, the IRS has issued a stern warning to taxpayers that unreported foreign accounts and income remain a top priority for enforcement. And your chance to seek shelter in the OVDP bunker before the IRS sniffs you down like a bloodhound is slowly fading. Since 2008, the …
Recent Tax Court Case Casts Light on CDP Shortcomings and Pitfalls Surrounding Reasonable Collection Potential
Listen When you drop a large rock into a pool of calm water, ripples appear and spread and eventually they will touch the entire surface of that pond, drastically changing its appearance. And the case of Gallagher v. Commissioner was a very big one indeed. Gallagher v. Commissioner is a great example of how things work …