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...

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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...

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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...

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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...

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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...

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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...

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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...

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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...

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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...

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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...

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