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The Bassin Law Firm, PLLC Files Suit Challenging Validity of New International Tax Regulations

by Stuart J. Bassin The Bassin Law Firm PLLC, representing two small business plaintiffs, recently challenged the validity of the transition tax regulations (formally published earlier today) in a complaint filed in the United States District Court for the District of Columbia against the Treasury Department and the IRS. The transition tax and the challenged

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Issuing Tax Refunds During Gov’t Shutdown May Be Unlawful

Author: Vidya Kauri   The Trump administration’s decision to permit tax refunds to be issued during a federal government shutdown could be deemed an unlawful exercise of the executive branch’s powers if IRS employees are forced to work without pay.   The IRS said it would recall furloughed employees as the government remained shut down

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More Thoughts on Release of President Trump’s Tax Returns

by Stuart J. Bassin My recent post on a potential Congressional effort to obtain and disclose President Trump’s tax returns generated a wave of comments and questions.  Setting aside a couple political rants, readers raised a number of questions which are worthy of comment.  So, let’s dive into the e-mail bag. What could we learn

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Can the House Obtain and Release President Trump’s Tax Returns?

  by Stuart J. Bassin Ever since the networks announced that the Democrats had retaken the House of Representatives, commentators have discussed whether the House would use that control to obtain and release President Trump’s tax returns.  Recognizing that the Internal Revenue Code might contain answers to those questions, I pulled out my tattered copy

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Ninth Circuit Reconsideration in Altera v. Commissioner

  by Stuart J. Bassin  Last week bought the latest twist in the saga of a challenge to a critical transfer pricing regulation—a rehearing by the Ninth Circuit of a since-vacated ruling upholding the regulation.  The original unanimous reviewed decision by the Tax Court in Altera Corp. v. Commissioner, 145 T.C., No. 3 (2015), invalidated

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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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