Laura L. Gavioli, PC, recently wrote an article for Law360 on a US Court of Appeals for the District of Columbia Circuit’s decision that may provide an equitable avenue for hearing of late-filed petitions in US Tax Court. The Law360 article, “Myers May Make It Easier to Find Equitable Relief in Tax Court,” can be
The Tax Court’s 2018 Judicial Conference starts tomorrow morning on the campus of Northwestern University’s Pritzker School of Law. For prior coverage, see here. The many panels taking place tomorrow and Wednesday include:
- Mediation in the Tax Court
- Discovery and Stipulations Process
- Litigating Individual Cases
- Large Case Litigation
- Whistleblower Jurisdiction
- A Trip Through the
Statutes in the Internal Revenue Code (Code), like statutes in other areas of the law, are filled with terms that invite differing interpretations. As a general rule, a statutory term should be given its normal and customary meaning. This might entail resorting to common dictionary definitions from Webster’s or Black’s Law Dictionary. It might also…
In a press call on August 2, 2017, the Chief of the Internal Revenue Service’s (IRS) Criminal Investigation Division (CID), John D. Fort, announced two new enforcement initiatives: a National Coordinated Investigations Unit and an International Tax Enforcement Group.
The National Coordinated Investigations Unit is intended to be, in Fort’s words, a “cutting edge” group answering directly to CID’s management. It is intended to harness data already being gathered by the IRS’s civil departments to identify areas of non-compliance, so that major investigations can be coordinated at a national level.
The first three areas of inquiry for the new unit will be international tax enforcement, employment tax enforcement and microcap stock fraud (an effort that will be coordinated with the Security and Exchange Commission). In Fort’s words, these efforts will generate “must-work referrals that come out of this group to the field offices.” International tax and employment tax enforcement are already longstanding CID priorities, so it will be interesting to see how CID’s use of data analytics will further those goals and whether greater coordination at the national level will result.…
This week, a French court announced an indictment against UBS related to its alleged treatment of Nicholas Forissier, a former audit manager who provided information to French authorities a decade ago in a tax evasion investigation of UBS. According to at least one press account, the indictment alleges that Forissier was “forced to work…