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Stu Bassin quoted in BNA and Tax Notes articles on Treasury Department announcement

Daily Tax Report Tuesday, October 10, 2017 Tax Audits: A Ban on Outside Lawyers in IRS Audits Is Past Due, Lawyers Say By Alison Bennett The possibility of a Treasury Department proposal to keep private-sector counsel out of tax examinations is getting mixed reviews. The idea, announced in an Oct. 4 report, calls attention to

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Law 360 Reviews Tax Court Petition for Administrative Costs Filed by The Bassin Law Firm

Ex-Arthur Andersen Exec Sues IRS After Tax Shelter Fight By Jimmy Hoover Law360, Washington (August 25, 2017, 5:51 PM EDT) — A onetime executive of defunct accounting firm Arthur Andersen LLP has sued the IRS for legal fees after he fought off its $1.6 million penalty over alleged tax-shelter promoting in the late 1990s, saying

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IRS Increases User Fee for Enrolled Agent Exam by 700 Percent

“Enrolled agents” are tax specialists authorized by the IRS to represent taxpayers in tax disputes in many of the same ways as tax attorneys and CPAs.  To obtain an “enrolled agent” designation, an applicant must pass an IRS competency examination.  Earlier this month, the IRS issued a regulation massively increasing the user fee applicants must

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Blog Post on Wells Fargo Decision

Wells Fargo Decision Answers Economic Substance Question Practitioners have debated the parameters of the economic substance doctrine for decades. A recent district court opinion in Wells Fargo & Co. v. United States, No. 09-CV-2764 (D. Minn. May 24, 2017), addressed and resolved one of the more interesting undecided questions regarding the relationship of the so-called objective

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Stu Bassin quoted by Bloomberg/BNA in article on proposed repeal of economic substance statute

Tax Shelters Side Effect of ACA Repeal Could Include Tax Shelters Snapshot  Economic substance doctrine change could make pro-tax shelter argument stronger  Tax shelter use has been on decline as IRS has gone after “abusive” transactions By Laura Davison The U.S. government would have a tougher time shutting down tax shelters if congressional Republicans successfully repeal

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Procedurally Taxing Blog Post on Summa Holdings

The Sixth Circuit’s Summa Bomb-shell February 24, 2017 We welcome back guest blogger Stu Bassin. Stu is a solo practitioner in Washington, D.C. who specializes in tax controversy work. Today he talks about Summa Holdings v Commissioner, where the Sixth Circuit disagreed with the IRS and Tax Court’s applying a substance over form analysis. The role

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Disclosure of Donald Trump’s Tax Returns

The New York Times recently published excerpts from Donald Trump’s 1995 tax returns.  Soon thereafter, Mr. Trump’s spokesmen charged that the Times violated federal law by   illegally disclosing Mr. Trump’s returns.  Invoking the First Amendment, the Times defended the publication.  Which side correctly read the tax law? The public generally believes that federal tax returns are confidential and

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“Procedurally Taxing” post on “Court of Federal Claims Authorizes Deposition of Revenue Agent and Requires Production of Service Documents in Tax Refund Suit”

We welcome back guest blogger Stu Bassin. Stu is a solo practitioner in Washington, D.C. who specializes in tax controversy work. Today he talks about a recent Court of Federal Claims case in which the Court rules on a discovery dispute that had several facets. The taxpayer in the case before the Court had not participated

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IRS’ Quinn Emanuel Retainer Is A Wrongheaded Experiment

New York (April 26, 2016, 11:24 AM ET) Should the government rely on private law firms to perform its legal work? Privatization of government litigation has occurred for years, but not without controversy.  Law360’s Expert Analysis special series explores the issue from the points of view of a former IRS counsel, a former attorney general and

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Sixth Circuit Requires IRS to Disclose Return Information of Non-Parties in Tea Party Exempt Organization Litigation

Last week, the Sixth Circuit rejected a government mandamus petition seeking to overturn a trial court discovery order requiring the Service to disclose the names of non-party organizations whose applications for tax exempt status were allegedly treated improperly because of the organization’s political views. In re United States; United States v. NorCal Tea Party Patriots, Case No.

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