By Kevin Spencer and Macdonald Norman on Apr 22, 2020
Posted In Appellate Courts, Tax Refunds, Trial Courts, Uncategorized
The United States Court of Appeals for the Tenth Circuit’s recent opinion in Standing Akimbo, LLC v. United States, No. 19-1049 (10th Cir. April 7, 2020), reminds us of the Internal Revenue Service’s (IRS) ability to obtain the information it needs to examine taxpayers’ returns using its powerful summons tool. In May 2017, the IRS...
By Kevin Spencer and Macdonald Norman on Sep 17, 2019
Posted In IRS Audits, IRS Guidance, Transfer Pricing Resource, Uncategorized
The Large Business and International Division of the Internal Revenue Service (IRS) developed the Compliance Assurance Process (CAP) program to improve large corporate taxpayer compliance with US federal tax obligations through the use of real-time issue resolution tools and techniques. On September 12, 2019, the IRS announced that it was accepting applications—for the first time...
By Kevin Spencer and Macdonald Norman on Apr 23, 2019
Posted In Appellate Courts, IRS Guidance, Trial Courts, Uncategorized
When you do not pay your taxes, the Internal Revenue Service (IRS) has the power to file a “lien” on your property under Internal Revenue Code section 6321. The lien attaches “upon all property and rights to property, whether real or personal, belonging to such person.” Practically, this means that the IRS is giving notice...
By Macdonald Norman on Feb 7, 2019
Posted In Trial Courts, Uncategorized
On the February 6, 2019, the White House announced that President Donald Trump has renominated Mark Van Dyke Holmes, Courtney Dunbar Jones, Travis Greaves and Emin Toro to 15-year terms on the United States Tax Court. President Trump nominated each candidate in 2018, but the Senate was not able to confirm their appointments prior to...
White House Intends to Nominate Michael J. Desmond to High-Level Roles in the IRS and the Department of Treasury
By Kevin Spencer, Macdonald Norman and McDermott Will & Emery on Mar 5, 2018
Posted In Court Procedure Matters, IRS Guidance, Trial Courts, Uncategorized
The White House announced on March 2 that the president intends to nominate Michael J. Desmond, a prominent tax lawyer, to be the Chief Counsel for the Internal Revenue Service (IRS) and Assistant General Counsel in the Department of Treasury. Subject to approval by the Senate, Mr. Desmond’s new roles will entail providing legal guidance...
By John Robert, Kevin Spencer and Macdonald Norman on Oct 6, 2017
Posted In IRS Guidance, Uncategorized
On September 21, the Internal Revenue Service (IRS) released Revenue Procedure 2017-52 which introduces an 18 month pilot program expanding the scope of the IRS’s ruling practice with respect to distributions under Internal Revenue Code (Code) Section 355. Prior to Revenue Procedure 2017-52, the IRS had determined that it would not issue letter rulings on...
By Macdonald Norman and Robin L. Greenhouse on Jul 31, 2017
Posted In Court Procedure Matters, Trial Courts, Uncategorized
In Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc. 467 US 837 (1984), the Supreme Court of the United States established a framework for assessing an agency’s interpretation of statutory provisions. First, a reviewing court must ask whether Congress “delegated authority to the agency generally to make rules carrying the force of law,” and...
By Kevin Spencer and Macdonald Norman on Jul 26, 2017
Posted In Alternative Dispute Resolution, IRS Appeals, Settlements, Uncategorized
The Internal Revenue Service Office of Appeals (IRS Appeals) recently announced that it will offer a new virtual “face-to-face” option in the form of web-based communication to taxpayers and representatives to resolve tax disputes. IRS Office of Appeals Pilots Virtual Service, IRS (July 24, 2017. This announcement comes on the heels of other changes at...