The Unanswerable Discovery Request

Have you ever been asked a question that you should probably know the answer to, but you don’t fully know the answer or have access to information to find the actual answer? This is a frequent occurrence when it comes to litigation and, in particular, tax litigation. The litigation discovery process involves exchanging relevant information……

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Recovering Legal Expenses for Mistaken IRS Audit of Non-Resident

The U.S. has significant and complex reporting and filing and notice requirements. This includes a myriad of state and local requirements and federal requirements, including income tax return filing requirements. As odd as it sounds, it is part of what makes America great. We often don’t think about it, but these filing requirements are part……

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Using Accounting Records in Tax Court

Whether one likes it or not, the federal government is their business partner. The tax code is often compared to a partnership agreement that sets out the share of the income that belongs to the federal government. Continuing the analogy, the records the business keeps are the support for making the allocation between the taxpayer……

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Tax Court Review of IRS SS-8 Employment Determination

The IRS has the power to make a number of important determinations, including determining the employment status of workers for purposes of employment taxes. This type of determination can have a significant impact on a worker’s ability to receive unemployment benefits, participate in retirement plans, and more. The IRS often determines that workers are employees,……

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