Cleaning Up After The Elephants – A Practical Reminder On Document Preservation Policies and Litigation Holds In Tax Disputes

By Phil Karter Any corporate tax executive who has ever been involved in contesting an audit adjustment knows all too well how unfavorable documents relating to the subject of the adjustment – particularly improvident comments reflected in email correspondences – can be an ongoing impediment to resolving a tax dispute from the audit phase right … More Cleaning Up After The Elephants – A Practical Reminder On Document Preservation Policies and Litigation Holds In Tax Disputes

The IRS Can Summons California For Property Transfer Records

As noted by Janet Novack at forbes.com, Judge England of the District Court for the Eastern District of California last week issued an order permitting the IRS to serve a “John Doe” summons on the California State Board of Equalization.  The summons seeks the names of residents who transferred property to relatives for little or … More The IRS Can Summons California For Property Transfer Records

Musings in the Aftermath of the First Schedule UTP Filing Season

By Phil Karter As reported earlier this week in the tax press, the recently completed initial filing season for Schedule UTP produced at least one major surprise in the eyes of IRS officials, who had anticipated a much greater number of items listed on the average Schedule UTP than actually materialized.  In fact, the IRS’s … More Musings in the Aftermath of the First Schedule UTP Filing Season

Using Non-Tax Sources To Fight Tax Battles: Are You Exposed?

By Jonathan Prokup In the last two weeks, various news sources have reported on a previously low-profile IRS initiative to use state land-transfer records to identify potential omissions in reporting gifts of real estate.  (Via TaxProf here and the WSJ here.)  According to the reports, the IRS is using information received from at least 16 … More Using Non-Tax Sources To Fight Tax Battles: Are You Exposed?

Tax Blawg Report on IRS National Employment Tax Research Project

The IRS National Employment Tax Research Project has started.  On November 9, 2009 the IRS announced its first employment tax research project in 25 years.  Under the program, which will last from 2010 through 2012, the IRS will audit 6,000 employers randomly selected from all employment tax filers.  It is our understanding that the initial … More Tax Blawg Report on IRS National Employment Tax Research Project