What is the July 10, 2026 deadline about and do I need to file a claim with the IRS? In advance of a July 10, 2026…
Take Accountability, Implement Procedural Safeguards, and Read (and Follow) the Rules On May 18, 2026, Kenneth Salinger, Justice of the Superior Court of the Commonwealth of…
The Fourth Circuit holds that the plain language of the innocent spouse statute (IRC § 6015(f)(1)) means that underpayment interest the IRS erroneously refunded is a…
How a “Gift Letter” (Contemporaneous Written Acknowledgment or CWA) Failed the Strict Substantiation Requirements in the Tax Code May 15, 2026 – This week, the Tax…
Is the Fourth Time a Charm? The IRS is now offering a fourth settlement initiative for eligible taxpayers involved in syndicated conservation easement disputes. This offer,…
The IRS can reduce taxes, interest, and penalties (civil or criminal) through an offer-in-compromise (i.e., an “OIC”). An OIC is an offer by a taxpayer to…
Olive Picking is a painting by Vincent van Gogh. In it, he used his signature brush lines to capture women picking olives in an olive grove….
Tax Court Holds that a Notice Received and Challenged is Valid Notwithstanding that it was Sent to the Wrong Partnership Representative and Wrong Address, Mammoth Cave…
Although the nuances of conservation and preservation efforts have changed, North Carolinians and their elected officials have demonstrated a commitment to protecting the lands and historic…
Feb. 18, 2026 – This month, the U.S. Tax Court issued a memorandum opinion in El v. Commissioner, T.C. Memo. 2026-17, a case where the IRS…