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The IRS is After Me. What Now?

  You just received mail from the IRS (and it isn’t a refund check).   The good news.  The IRS may not actually be after your money.  Sometimes, it is a simple request for a specific document, like a receipt for a charitable contribution.  Or, the IRS can be correcting a minor math error you

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American Institute of Certified Public Accountants v. Internal Revenue Service — A Contrary Perspective

The D.C. Circuit’s recent decision in AICPA v. Internal Revenue Service[1] allowed the Service to continue its voluntary Annual Filing Season Program—a program which grants unlicensed tax return preparers with limited rights to represent taxpayers during audits if they satisfy continuing professional education requirements and pass a competency examination.  In a recent post, Professor Book

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Stu Bassin Speaks at Hearing Challenging Legality of Proposed Regulations Allowing IRS to Hire Outside Lawyers for Audits

The Bassin Law Firm submitted written comments and Stu Bassin provided live testimony at a recent hearing on proposed regulations which would authorize the IRS to hire outside lawyers to participate in development and litigation of tax disputes.   Until recently, the IRS had not hired outside lawyers to participate in development and litigation of

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OUTLINE OF ANTICIPATED TESTIMONY ON PROPOSED SECTION 7602 REGULATIONS RELATING TO PARTICIPATION OF NON-GOVERNMENTAL ATTORNEYS IN AUDITS

    My background 30 years of tax controversy practice (20 with DOJ, 10 in private practice) Principal contributor to Section 6103 discussion in Saltzman/Book treatise on IRS Practice and Procedure Author of published material on issues addressed in proposed regulations Summary of comments Describe four categories of non-governmental participants in audits addressed by proposed

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Did the IRS Just Buy Off the Tea-Party?

You may have missed the small item in the tax press describing the latest embarrassment for the Service arising out of the agency’s handling of applications for tax exempt status submitted by “tea party” organizations. The taxpayers, their supporters in the press, and many in Congress have long contended that the IRS action was politically

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Another Circuit Court Upholds DISC Retirement Account Transaction|
Stu Bassin quoted in Tax Notes article

By Nathan J. Richman The IRS has lost a second appeal of its attempt to reclassify transactions between a domestic international sales corporation and Roth IRAs, unsuccessfully arguing that the substance-over-form doctrine should apply. According to Stewart Karlinsky, executive director of the Pacific Tax Policy Institute, the result shows it is time for Congress to

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The Next Government Shutdown: A Legal Perspective

Published in on February 12, 2018 We welcome back guest blogger Stuart J. Bassin who writes about a topic recently on everyone’s mind, the government shutdown. Whether you are a government employee who must spend endless hours at the water cooler discussing whether you will come to work or someone impacted by the shutdown or threat of

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Reality Debunks Myths of Corporate Tax Reform

We all know the talking points underlying the corporate tax reform provisions in the recent tax legislation. We were told that corporations were taxed at a roughly 35 percent rate, that tax reform would reduce corporate tax liabilities, and that the reform would make billions available for new projects to boost the economy.   Now that

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Is IRS Backing Away From Its Transfer Pricing Initiative

In recent years, transfer pricing issues have been a major priority for IRS audits.  While the IRS has made headlines by bringing a number of big-dollar cases against large multi-nationals, the courts have not been impressed.  Within the past few years, the IRS has lost a number of major transfer pricing cases.  Many of those

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Last Minute Tax Planning For Maryland Residents (and others)

December 26, 2017 by Stuart Bassin You have probably heard that one “feature” of the new tax law is its treatment of deductions for state and local taxes.  To simplify, under the new law, deductions for state and local taxes (both income and property) are generally limited to $10,000, beginning in 2018.   For those of us

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