How Long Does The IRS Have To Audit Your Return?
People are always asking how long the IRS can wait from the time you file your return to conduct an audit of your income and expenses. The simple, most definitive answer is "it all depends," so let's...
View ArticleBeard v. Comm'r: Basis Overstatement Is An Omission Of Gross Income
The Seventh Circuit handed the government a victory yesterday, deciding in Beard v. Comm’r that a taxpayer’s overstatement of basis can result in an omission of income under Code section 6501(e),...
View ArticleInnocent Spouse Relief After Mayo: Congress Strikes Back?
Following the Supreme Court’s decision in Mayo Foundation v. United States, in which the Court ruled that tax regulations receive deference from courts under the Chevron doctrine that applies to...
View ArticleA Concrete Show for Brand X?
David J. Shakow is counsel in the Philadelphia office of Chamberlain, Hrdlicka, White, Williams & Aughtry and is professor emeritus at the University of Pennsylvania Law School. The Supreme Court's...
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