Our tax attorneys provide sophisticated tax advice covering such matters as individual income tax planning; complex estate planning; business tax planning; tax compliance; representation during examinations of returns and collection of delinquent tax debts; criminal tax matters; administrative appeals process; tax litigation in state and federal courts; and international tax compliance and enforcement.

Revenue Procedure 2019-09: What Constitutes Adequate Disclosure for Purposes of Avoiding Penalties

The IRS recently published Revenue Procedure 2019-09, which is the Service’s annual pronouncement identifying the circumstances under which a disclosure on a taxpayer’s income tax return will be deemed sufficient for purposes of reducing an understatement of income...

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