Jenny L. Johnson Ware
By Andrew R. Roberson, Kevin Spencer and Jenny L. Johnson Ware on May 28, 2021
Posted In Appellate Courts, Court Procedure Matters, IRS Audits, IRS Guidance, Trial Courts
In CIC Services, LLC v. Internal Revenue Service, a unanimous US Supreme Court allowed CIC, a tax advisor, to proceed with a pre-enforcement challenge to the Internal Revenue Service’s (IRS) “reportable transaction” regime. CIC alleged that the IRS violated the Administrative Procedure Act (APA) when it issued Notice 2016-66 (Notice), deeming certain micro-captive insurance transactions...
By Jenny L. Johnson Ware, Andrew R. Roberson and Kevin Spencer on Oct 22, 2020
Posted In Court Procedure Matters, Trial Courts
The US Tax Court (Tax Court) recently announced upcoming changes to its case management system. DAWSON (Docket Access Within a Secure Online Network), named after former Tax Court Judge Howard A. Dawson, Jr., who passed away in 2016, is expected to be active by the end of 2020. To facilitate the transition to DAWSON, the...
By Jenny L. Johnson Ware, Andrew R. Roberson, Kevin Spencer and Le Chen on Jul 16, 2020
Posted In IRS Appeals, IRS Audits, IRS Guidance, Tax Reform
If you have knowingly failed to report income or claimed deductions you know you are not entitled to, or just decided not to file your tax returns and pay the tax owed, you may be liable for civil penalties and even jail time for criminal tax evasion. Taxpayers with civil and criminal tax exposure may...