Since 1969, Internal Revenue Code (IRC) section 162(f) has disallowed an ordinary and necessary business deduction in computing taxable income for any civil or criminal…
The Death Knell for SALT Cap Workarounds?
Treasury’s Final Regulations Uphold the $10,000 Cap
The itemized deduction for state and local taxes (SALT) under Internal Revenue Code (IRC) section 164 had long provided relief to taxpayers residing in high…
On November 2, 2015, Congress enacted the Bipartisan Budget Act of 2015 (BBA), which contained sweeping changes to the Internal Revenue Code's (IRC) partnership audit,…
Under Internal Revenue Code (IRC) section 6672(a), an individual can be held personally liable for a penalty for the willful failure to collect, account for,…
Filing a claim for refund of overpaid tax involves much more than just submitting an amended return to the IRS with an explanatory statement that…