Kevin Spencer

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Kevin Spencer focuses his practice on tax controversy issues. Kevin represents clients in complicated tax disputes in court and before the Internal Revenue Service (IRS) at the IRS Appeals and Examination divisions. In addition to his tax controversy practice, Kevin has broad experience advising clients on various tax issues, including tax accounting, employment and reasonable compensation, civil and criminal tax penalties, IRS procedures, reportable transactions and tax shelters, renewable energy, state and local tax, and private client matters. After earning his Master of Tax degree, Kevin had the privilege to clerk for the Honorable Robert P. Ruwe on the US Tax Court. Read Kevin Spencer's full bio.

Weekly IRS Roundup June 3 – June 7, 2024


By , and on Jun 13, 2024
Posted In IRS Guidance, Tax Reform, Tax Refunds

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 3, 2024 – June 7, 2024. June 3, 2024: The IRS released Internal Revenue Bulletin 2024-23, which includes Revenue Procedure 2024-23. The revenue procedure provides an updated list of tax accounting method changes for which...

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Weekly IRS Roundup May 27 – May 31, 2024


By , and on Jun 6, 2024
Posted In IRS Guidance, Tax Reform, Tax Refunds

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 27, 2024 – May 31, 2024. May 28, 2024: The IRS released Internal Revenue Bulletin 2024-22, which includes the following: Revenue Procedure 2024-25, which provides the inflation-adjusted limits related to health savings accounts and high...

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Weekly IRS Roundup May 20 – May 24, 2024


By , and on May 31, 2024
Posted In IRS Guidance, Tax Reform, Tax Refunds

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 20, 2024 – May 24, 2024. May 20, 2024: The IRS released Internal Revenue Bulletin 2024-21, which includes the following: Treasury Decision 9992, which includes final regulations on the standards under which a qualified investment...

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Weekly IRS Roundup May 13 – May 17, 2024


By , and on May 24, 2024
Posted In IRS Guidance, Tax Reform, Tax Refunds

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 13, 2024 – May 17, 2024. May 13, 2024: The IRS released Internal Revenue Bulletin 2024-20, which includes proposed regulations concerning the excise tax on stock buybacks under § 4501 of the Internal Revenue Code...

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IRC Section 280E Will No Longer Apply if Marijuana Is Rescheduled


By and on May 21, 2024
Posted In Tax Refunds

On May 16, 2024, the US Department of Justice submitted a Notice of Proposed Rulemaking (NPRM) to reschedule marijuana from Schedule I to Schedule III within the Controlled Substances Act. As the NPRM recognizes, this action would have a significant economic impact on a substantial number of businesses – specifically, medical and recreational marijuana dispensaries...

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Weekly IRS Roundup May 6 – May 10, 2024


By , and on May 16, 2024
Posted In IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 6, 2024 – May 10, 2024. May 6, 2024: The IRS released Internal Revenue Bulletin 2024-19, which includes the following: Revenue Ruling 2024-09, which provides the May 2024 applicable federal rates. Notice 2024-35, which provides...

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Understanding the IRC’s Excessive Refund Claim Penalty


By , and on May 8, 2024
Posted In Court Procedure Matters, IRS Audits, Tax Refunds, Trial Courts

Recently, the Internal Revenue Service (IRS) has been asserting the Internal Revenue Code Section 6676 penalty much more frequently in examinations and in court. For example, in 2023, a government counterclaim in the US District Court for the Middle District of Georgia sought to recover Section 6676 penalties in Townley v. United States. And, internal IRS guidance requires examiners to consider...

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Weekly IRS Roundup April 29 – May 3, 2024


By , and on May 7, 2024
Posted In IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 29, 2024 – May 3, 2024. April 29, 2024: The IRS released Internal Revenue Bulletin 2024-18, which includes the following: Notice 2024-33, which provides a limited waiver of the addition to tax under Section 6655...

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Weekly IRS Roundup April 22 – April 26, 2024


By , and on May 2, 2024
Posted In IRS Guidance, Tax Reform, Tax Refunds

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 22, 2024 – April 26, 2024. April 22, 2024: The IRS released Internal Revenue Bulletin 2024-17, which includes the following: Proposed regulations, which would facilitate the transfer of tax return information to the US Census...

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Protect Yourself: Action Steps Following the Largest-Ever IRS Data Breach


By and on Apr 24, 2024
Posted In IRS Guidance

On January 29, 2024, Charles E. Littlejohn was sentenced to five years in prison for committing one of the largest heists in the history of the federal government. Littlejohn did not steal gold or cash, but rather, confidential data held by the Internal Revenue Service (IRS) concerning the United States’ wealthiest individuals and families. Last...

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