In Crandall v. Commissioner (available here), in a win for taxpayers who have gone through the IRS’s offshore voluntary disclosure program (OVDP), the United States Tax Court held that the IRS was bound by the terms of a closing agreement and could not assert a deficiency (or penalty) greater than
By Lawrence (Larry) Sannicandro Tax Notes State Volume 100 (posted on April 5, 2021) In the wake of major social and racial change, many organizations are making a concerted effort to promote diversity, inclusiveness, and equality in the workplace. These efforts are commendable, but more action is needed. For the
The Internal Revenue Service (IRS) and the U.S. Department of Justice (DOJ) recently showed their hands in their ongoing fight against tax noncompliance relating to cryptocurrency. The IRS is authorized by statute to issue John Doe administrative tax summonses to obtain information from third-parties regarding taxpayers whose identities are unknown.
Lawrence (Larry) A. Sannicandro was quoted in a recent article for Tax Notes entitled “Initial Remote Tax Court Proceedings Have Had Few Hiccups,” published on February 22, 2021. Sannicandro comments on his recent trial experience on the Tax Court’s Zoomgov platform and proffers several ways in which the remote proceedings
Lawrence (Larry) A. Sannicandro was quoted in a recent article for The Intercept entitled “Prisons Are Skimming Big Chunks of CARES Act Stimulus Checks,” published on February 17, 2021. Sannicandro comments on how some prisons have garnished funds from CARES Act stimulus checks that were issued to prisoners. The article