Prose by Tax Pros

The IRS believes that partnerships that engage in syndicated conservation easement transactions (“SCETs”) are claiming excessive tax deductions. The partnerships, on the other hand, point to congressional support for over 50 years, large amounts of pre-donation due diligence, full disclosure to the IRS, and reliance on a long list of experts. The two sides simply disagree, which is fine. What is not okay, though, is that in attacking SCETs, the IRS is utilizing extraordinary tactics that might negatively affect all taxpayers. The article suggests that those concerned about taxpayer rights, separation of powers, environmental protection and other large-scale matters might question whether numerous “wrongs” by the IRS are achieving a “right.” Read the full article here. About Hale E. Sheppard HALE E. SHEPPARD, Esq. (B.S., M.A., J.D., LL.M., LL.M.T.) is a Shareholder in the Tax Controversy Section of Chamberlain Hrdlicka and Chair of the International Tax Group.

To have success against the IRS, taxpayers must understand substantive tax law and procedure. Too many are clueless about the latter, which ultimately causes their downfall. This article analyzes a recent Tax Court case, Crandall v. Commissioner, using it as a springboard for learning important lessons about the effect of Closing Agreements with the IRS, unique steps in rectifying international tax issues, and procedural questions that often arise. Read the full article here. About Hale E. Sheppard HALE E. SHEPPARD, Esq. (B.S., M.A., J.D., LL.M., LL.M.T.) is a Shareholder in the Tax Controversy Section of Chamberlain Hrdlicka and Chair of the International Tax Group.

  Panicked people do not think clearly, and this applies to taxpayers facing large IRS liabilities. Some assume that they can escape unharmed if they can just keep the IRS at bay until they die or if they simply move their assets abroad. These theories sound good, but they are wrong because the IRS and courts have many tools for pursuing tax debts from parties related to deceased taxpayers and from those who make a run for it. This article explains international obligations that trigger liabilities, recent cases where the IRS pursued surviving spouses, executors, trustees, and fiduciaries, and the use of Repatriation Orders over time. Read the full article here. About Hale E. Sheppard HALE E. SHEPPARD, Esq. (B.S., M.A., J.D., LL.M., LL.M.T.) is a Shareholder in the Tax Controversy Section of Chamberlain Hrdlicka and Chair of the International Tax Group.