Denver IRS Practitioner Liaison Meeting Notes January 2018... I wasn't able to be present at the this most excellent semi-annual event but did send one of my top trusted lieutenants who came back with the following notes and permission to…
The IRS Office of Appeals offers taxpayers an opportunity to resolve their tax disputes without going to court. Appeals is an independent function within the IRS that provides an impartial review of your tax dispute. Appeals also offers mediation services…
I have many clients in the entertainment industry and appreciate them all. The ones that fly to Denver to meet with me are my favorite as they tend to be the most disciplined. You are applauded on and off the…
In Coca Cola's SEC 8-K filing last week we learned that the IRS issued a $3.3 Billion statutory notice of deficiency against the company as the result of a 5 year long transfer pricing audit covering tax years 2007-09. This is very BIG when…
As many of you know who follow my tax musings via this blog, I recently led a team of people that shepherded a Marijuana Dispensary through the IRS Examination and Appeals functions. The dispensary in question was owned and operated…
Schumann v. IRS: Reg. 1.469-2(f)(6) - The Nuanced Relationship Between Passive Losses & Self Rental Gains. Back to my friends that I previously wrote about who misunderstood passive activity and material participation. They are a married couple filing jointly and own…
The SCOTUS clarified the 11th Circuit Court of Appeals in the United States v. Clarke Et. Al. that… “a taxpayer has a right to conduct an examination of IRS Officials regarding their reasons for issuing a summons when (s)he points to specific facts or circumstances plausibly…
IRS PTIN: P00605639
Enrolled Agent #: 85353
Email: john@johnrdundon.com
