IRS Examination
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IRS Examination

Harrison Smith and Justin Abold-LaBreche are improving IRS communication efforts.  As Co-Directors of the IRS Enterprise Digitalization and Case Management Office with experience across multiple IRS offices, they spearhead efforts to modernize systems, simplify business processes, and empower employees to rapidly resolve issues in simplified...

Protecting Americans from Tax Hikes Act of 2015 (PATH) summarized by my friend Shirley Callahan EA. Some highlights include: Everyone will appreciate the permanency of the enhanced Educator Expenses, the Sales Tax deduction, and the R&D Credit. Section 179 is made permanent at $500,000 phasing out at...

In Coca Cola's SEC 8-K filing last week we learned that the IRS issued a $3.3 Billion statutory notice of deficiency against the company as the result of a 5 year long transfer pricing audit covering tax years 2007-09. This is very BIG when it comes to enforcement of IRC...

As many of you know who follow my tax musings via this blog, I recently led a team of people that shepherded a Marijuana Dispensary through the IRS Examination and Appeals functions. The dispensary in question was owned and operated by a taxpayer who in...

Schumann v. IRS: Reg. 1.469-2(f)(6) - The Nuanced Relationship Between Passive Losses & Self Rental Gains. Back to my friends that I previously wrote about who misunderstood passive activity and material participation. They are a married couple filing jointly and own a very successful business together structured...

Meeting Summary as produced by IRS Senior Stakeholder Liaison Deborah Rodgers Nancy Carver, IRS Local Area Counsel Counsel continues to assist in training employees on partnership audits, and TEFRA. Counsel is also assisting in the investigations of promoters. Virtual currency is on the radar for Internal Revenue Service. Controlling...

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