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A taxpayer victory this spring in a captive insurance dispute involving promoter penalties shows that despite the IRS’s willingness to litigate such cases, the government won’t automatically be successful—particularly in terms of its burden to establish taxpayer knowledge in these cases. Read full article >
The IRS recently announced its plan to utilize its Inflation Reduction Act funding to shift its enforcement efforts on a certain subset of filers in an attempt to “restore fairness in tax compliance.” One such subset of filers specifically mentioned in the bulletin are large complex partnerships, of the type commonly seen in the various…
The Delaware Department of Insurance (DDOI) recently announced it appealed the Third Circuit’s decision in United States of America v. Delaware Department of Insurance, which involved the application of the McCarran Ferguson Act (MFA) to an IRS summons. The plot thickened on July 26 after Judge Alito requested briefing on the issue. The story abruptly…
Whistleblower attorneys Stephen M. Kohn and Dean Zerbe are pleased to announce that a joint client – who wishes to remain anonymous – received an IRS whistleblower award of $16.8 million. The whistleblower provided the IRS with information that led to an enforcement action against 86 high-wealth individuals who had engaged in a sophisticated illegal tax evasion scheme. The enforcement action…
The law firm of Zerbe, Miller, Fingeret, Frank, Jadav & Hunziker LLP (“ZMF Law”) announced today that two of its whistleblower clients received an award totaling $8.8 million dollars based on their information leading to the Internal Revenue Service (“IRS”) collecting approximately $35 million dollars in corporate income taxes. Read full press release here >
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