In November 2020, the U.S. Department of Justice (“DOJ”) experienced a cryptocurrency “windfall” of assets. It seized more than $1 billion of Bitcoin as part of a civil forfeiture complaint stemming from the Silk Road investigation and prosecution. Silk Road was the most sophisticated and extensive criminal marketplace… Read More
Blog
Two Bites at the Same Apple: CDP Hearing and IRS Appeals
The IRS has long taken the position, and the Tax Court has agreed, that a taxpayer is not permitted to challenge an assessed tax in a Collection Due Process (CDP) hearing if the taxpayer had a prior opportunity to contest the tax before IRS Appeals. That position reads… Read More
Intersection Between IRS Audits and IRS Criminal Investigation
Do not be lulled to sleep by your IRS Audit. And be particularly mindful if you have an “eggshell” audit. An “eggshell” audit is an audit situation where a taxpayer has damaging information, maybe even criminal behavior, that the IRS Examiner does not know about. In that case,… Read More
Scope of Tax Attorney-Client Privilege
The Attorney-Client privilege is one of the most important, fundamental, and respected protections between a client and his attorney. Because an attorney cannot divulge client confidences (and cannot – in most instances – be forced to), it fosters an open and honest environment. It is critical and central… Read More
Claims for Refund: Two Sides to the Story
Claims for refund come in two part. The parts are found in Section 6511(a) and (b). First, Section 6511(a) requires claims for the refund to be filed within a period of three years from the time the tax return was filed or two years from the time the… Read More
IRS Extends the Olive Branch: The Taxpayer Relief Initiative
As part of the new Taxpayer Relief Initiative, the IRS is making it easier to set up payment arrangements, installment agreements and Offers in Compromise. This initiative is in response to the challenges created by COVID-19 pandemic. Short-term payment plans extended to 180 days, up from 120 days…. Read More