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…