Jenny L. Johnson Ware

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Jenny L. Johnson Ware focuses her practice on complex tax disputes for private clients, their trusts and estates, and closely-held businesses. To successfully navigate these controversies, Jenny draws on tools she honed over years of experience trying tax cases: earning credibility, building a compelling factual record, and – perhaps most important – understanding that the art of crafting a winning closing argument begins years before trial. Read Jenny L. Johnson Ware's full bio.

District Court Vacates, Sets Aside IRS Reportable Transaction Notice


By , and on Mar 23, 2022
Posted In Appellate Courts, Court Procedure Matters, IRS Audits, IRS Guidance, Trial Courts

The fallout from taxpayer challenges to the Internal Revenue Service’s (IRS) “reportable transaction” regime continues. On March 21, 2022, the district court in CIC Servs., LLC v. IRS ruled in favor of the taxpayer, vacating Notice 2016-66 and ordering the IRS to return all documents and information produced pursuant to Notice 2016-66 to taxpayers and material...

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Sixth Circuit Sides with Taxpayer in APA Challenge to Reportable Transaction Regime


By , and on Mar 7, 2022
Posted In Appellate Courts, IRS Appeals

We previously posted about the US Supreme Court’s opinion in CIC Servs., LLC v. IRS, which allowed a pre-enforcement challenge to the Internal Revenue Service’s (IRS) “reportable transaction” regime. In that post, we noted the district court opinion in Mann Construction, Inc. v. United States, No. 1:20-cv-11307 (E.D. Mich. 2021), holding that an IRS Notice...

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IRS Chief Counsel Signals Increased Tax Enforcement


By , and on Jan 27, 2022
Posted In Appellate Courts, Court Procedure Matters, IRS Appeals, IRS Audits, IRS Guidance, Trial Courts

The Internal Revenue Service (IRS) Chief Counsel is the chief legal advisor to the Commissioner of Internal Revenue on all matters pertaining to the interpretation, administration and enforcement of the Internal Revenue Laws. In this regard, the IRS Office of Chief Counsel is responsible for litigating cases in the US Tax Court. Such cases can...

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Supreme Court Opens Door to APA Challenge of Overreaching IRS Information Reporting Regime


By , and 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...

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Tax Court to Update Case Management System


By , and 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...

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Skip Jail and Clean Up Your Tax Problems


By , , and 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...

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