Prose by Tax Pros

    Defeating the IRS is joyous, but winning and then obligating the IRS to pay legal, accounting, expert and other fees is sublime. The mechanism for achieving this elusive double victory is found in Section 7430. This article describes key aspects of fee recoupment under Section 7430, three recent cases, procedural rules on which the IRS depends in issuing notices devoid of meaningful information, and why fee reimbursement actions might increase in the near future. 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.

  Kicking people when they are down is one thing, but doing it repeatedly is another. Several recent cases demonstrate that the IRS is doing exactly that. This process, often referred to as “stacking” penalties, means imposing multiple sanctions against the same taxpayer, for the same year, in connection with the same problem. The article explains common U.S. international tax duties, the current “compliance campaign” focused on foreign trusts, and two recent cases showing how the IRS uses penalty stacking as a serious enforcement tool. 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.