Welcome to TaxBlawg, a blog resource from Chamberlain Hrdlicka for news and analysis of current legal issues facing tax practitioners. Although blawg.com identifies nearly 1,400 active “blawgs,” including 20+ blawgs related to taxation and estate planning, the needs of tax professionals have received surprisingly little attention.
Tax practitioners have previously lacked a dedicated resource to call their own. For those intrepid souls, we offer TaxBlawg, a forum of tax talk for tax pros.
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Back in July 2022, the media reported that two of President Trump’s rivals, former FBI Director James Comey and his deputy, Andrew McCabe, had both been selected for IRS examinations under the National Research Program (NRP). There were allegations that President Trump had sicced the IRS on his political foes. That Comey and McCabe were both selected for NRP audits seemed at best a statistical anomaly given the low nationwide audit rate. At worst, it conjured images of Nixon’s enemies list.
In a report dated November 28, 2022, the Treasury Inspector General for Tax ...
During IRS audits, we routinely encounter examining agents who become suspicious (even apoplectic) when the audit trail from the client’s general ledger to source documents is imperfect. Well, it turns out the IRS may be throwing stones in their own glass house. The IRS reports to Congress and other external parties the size of its unpaid tax debts to justify its requests for enhanced resources for tax enforcement, and for other informational purposes. The gross receivable is taken from the agency’s general ledger.
According to a General Accounting Office (GAO) report issued ...
For decades, tax audit procedures for partnerships had been governed by a framework established in the Tax Equity and Fiscal Responsibility Act of 1982. This partnership audit regime was commonly referred to as the TEFRA partnership procedures, or simply TEFRA. In 2015, in response to widespread criticism over the complexities of TEFRA, Congress replaced TEFRA with a new audit regime under the Bipartisan Budget Act of 2015, now the BBA partnership procedures.
The BBA partnership procedures have been phasing in, with the first wave of partnership audits applying the BBA still ...