Tax Controversy & Enforcement

Individuals and businesses struggled during COVID, and many were unable to keep up with their tax obligations.  Thanks to a federal court decision in Kwong v. United States, taxpayers may be able to obtain refunds or penalty abatements for IRS penalties and interest attributable to the 2019 through 2021 tax years.  Critically, for taxpayers…

An IRS examination is an administrative process in which the IRS evaluates a tax return for the taxpayer’s reported positions, determines whether the underlying facts support those positions, and decides whether to propose adjustments.  Understanding the IRS examination process from return selection through the stages of an audit provides taxpayers who are considering how to…