By Bryan C. Skarlatos and Megan L. Brackney Journal of Tax Practice & Procedure October – November 2016 Edition Tax practitioners often give tax advice on things like how to structure an investment in a business venture, sell an asset, plan for retirement or pass wealth to the next generation. Sometimes a practitioner’s
By Bryan C. Skarlatos Journal of Tax Practice & Procedure January 01, 2014 The normal statute of limitations is three years from the date the return is filed. That is how long the IRS has to challenge the accuracy of the return and assess a deficiency.1 However, the three-year statute
By Bryan C. Skarlatos Journal of Tax Practice & Procedure January 01, 2014 The normal statute of limitations is three years from the date the return is filed. That is how long the IRS has to challenge the accuracy of the return and assess a deficiency.1 However, the three-year statute
By Megan L. Brackney Journal of Passthrough Entities September 01, 2013 The tax matters partner (“TMP”) of a TEFRA1 partnership has important duties where there is an IRS audit or controversy. One question that TMPs ask is whether a failure (or a perceived failure) to perform these duties will subject him