Who Audits TIGTA?

By George W. Connelly The Inspector General for Tax Administration, TIGTA, has been in the news a lot lately. In addition to tracking down misbehaving IRS employees and misbehaving representatives, an important role of this organization seems to be examining every aspect of the operation of the Internal Revenue Service and publishing a critical report about … More Who Audits TIGTA?

Where Does the IRS Get Off Telling You How to Run Your Business?

By George W. Connelly When the IRS audits a tax return involving a business, its agents invariably get involved in questions of recordkeeping and how transactions are conducted and recorded.  All too often, an IRS Examiner will suggest that a taxpayer’s records are not “adequate,” or that in some fashion the taxpayer is not operating in … More Where Does the IRS Get Off Telling You How to Run Your Business?

Will IRS Limit Exam’s Assertion of the Economic Substance Penalty? TIGTA Report Suggests Not.

Since codification of the economic substance doctrine in March 2010, taxpayers have expressed fears that IRS will assert the doctrine unpredictably, resulting in an in terrorem effect among taxpayers because of the lack of clear authorities interpreting the doctrine and the new 40% strict-liability penalty for falling on the wrong side of it.  To promote … More Will IRS Limit Exam’s Assertion of the Economic Substance Penalty? TIGTA Report Suggests Not.