If a taxpayer has a “substantial understatement” of income tax, the Internal Revenue Service (“IRS”) can assert a penalty. In fact, the IRS’s default procedure is…
Recently, the Tax Court issued a memorandum opinion in Paschall v. Commissioner, T.C. Memo. 2026-46, holding that the cryptocurrency proof-of-stake rewards at issue in that case…
Open letter to Mr. Taxpayer Mr. Taxpayer, you quit too soon. Perhaps you were worn down by the prison sentence for willful failure to file tax…