The U.S. Tax Court recently held that the Internal Revenue Service (“IRS”) lacked statutory authority to assess Internal Revenue Code (“IRC”) Section 6038(b) penalties against an individual for failure to file Forms 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations. The case has ramifications for any taxpayer that has been assessed…
Specialists in Tax Litigation
News
IRS Whistleblower Receives $16.8 Million Award for Exposing Widespread Tax Evasion Scheme
Whistleblower attorneys Stephen M. Kohn and Dean Zerbe are pleased to announce that a joint client – who wishes to remain anonymous – received an IRS whistleblower award of $16.8 million. The whistleblower provided the IRS with information that led to an enforcement action against 86 high-wealth individuals who had engaged in a sophisticated illegal tax evasion scheme. The enforcement action…
Tax Whistleblowers Get $8.8 Million Dollar Reward as IRS Revisits Earlier Decision and Triples Award Amount
The law firm of Zerbe, Miller, Fingeret, Frank, Jadav & Hunziker LLP (“ZMF Law”) announced today that two of its whistleblower clients received an award totaling $8.8 million dollars based on their information leading to the Internal Revenue Service (“IRS”) collecting approximately $35 million dollars in corporate income taxes. Read full press release here >
NOT SO INDEPENDENT CAYLOR – THE NEWEST RULING ON “MICRO-CAPTIVES” FROM THE IRS
On Wednesday, March 10, the Tax Court issued its fourth case concerning “Microcaptive” insurance companies. In Caylor Land & Dev. v. Comm’r, the IRS continues its winning streak against captive arrangements. In the words of Judge Holmes, who authored the opinion as well as that of the seminal Avrahami case, “We will break no new…
ZMF SECURES APPRAISAL VICTORY FOR ELDERLY FAMILY
For residential and commercial property owners alike, the appraisal process can be as nebulous as it is unfamiliar. Many times, policyholders find themselves not only pitted against their own insurance carrier, but also the very contractors and appraisers who they retained to advocate on their behalf. Worse yet, appraisal can become a protracted process due…
