Tag Archives: DOJ

President Trump Nominates Copeland and Urda to US Tax Court

On August 3, 2017, President Donald Trump nominated two judges to the US Tax Court. The nominations were received in the US Senate (Senate) and referred to the Committee on Finance. One of the nominees, Elizabeth Copeland, was previously nominated by President Barack Obama. Her previous nomination expired with the conclusion of the 114th Congress … Continue Reading

Overview of Tax Litigation Forums

Taxpayers can choose whether to litigate tax disputes with the Internal Revenue Service (IRS) in the US Tax Court (Tax Court), federal district court or the Court of Federal Claims. Claims brought in federal district court and the Court of Federal Claims are tax refund litigation: the taxpayer must first pay the tax, file a … Continue Reading

Taxpayer Advocate Questions IRS CID’s Narrow Reading of the Taxpayer Bill of Rights

On March 30, 2017, the US Treasury Inspector General for Tax Administration (TIGTA) published a report identifying numerous violations of taxpayer rights from 2012 to 2014 by the Internal Revenue Service Criminal Investigation Division (IRS CID) in structuring cases. TIGTA examined over 300 investigations for structuring in this time period and identified 21 cases in … Continue Reading

Change in Leadership at DOJ Tax Division

The Department of Justice (DOJ) Tax Division is responsible for litigating tax refund claims brought in Federal district courts and the Court of Federal Claims and handling appeals from decisions of the United States Tax Court (the Chief Counsel’s office is responsible for Tax Court litigation).  Effective January 23, 2017, David A. Hubbert became the … Continue Reading

What to Expect During a Change of Administration

With the inauguration of President Trump, and the accompanying change of administration, the American people have been promised great change in all areas of the federal government. One question we at McDermott have been frequently asked since the election is: what should a taxpayer expect from the Internal Revenue Service (IRS) and the Department of … Continue Reading

Facebook Battles IRS In Summons Enforcement Case

Facebook is in a protracted battle with the IRS related to its off-shoring of IP to an Irish affiliate. Read more here. The IRS issued an administrative summons for the documents, and Facebook has refused to comply with the summons. The IRS is asking the court to enforce the summons and force Facebook to turn … Continue Reading
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