Charles Ruchelman

TIME SENSITIVE: IRS Offers Voluntary Disclosure Program For Employee Retention Credit Taxpayers

IRS Offers Voluntary Disclosure Program For Employee Retention Credit Taxpayers

Further Criticism Of The Procedure In Liberty Global

Tax Court Rules That IRS Lacks Statutory Authority To Assess Penalties For Failure To File Form 5471

Evaluating And Improving The Taxpayer Rights Provisions Of The IRS Restructuring And Reform Act Of 1998

IRS Takes Aim At Law Firms' Deferred Payment Arrangements For Contingency Cases

IRS To Issue Proposed Regulations Identifying Syndicated Conservation Easements As Listed Transactions

Obtaining Refunds Of Section 6707A And Section 6707 Penalties Paid For Not Properly Reporting Listed Transactions Or Transactions Of Interest (Including Notice 2007-83 And Notice 2016-66)

Taxpayer Defeats IRS Penalty In Tax Court For Conservation Easement Transaction

IRS "Dirty Dozen" List Includes "Potentially" Abusive Use Of U.S.-Malta Tax Treaty In Pension Plans