The Taxman Cometh: IRS Audit Focus on Middle Market Companies

In a recent speech at the mid-year conference of the Tax Executives Institute, IRS Deputy Commissioner Steven T. Miller laid out the framework for the future of IRS corporate audits. To borrow Mr. Miller's own assessment, this is bad news for large corporate taxpayers in the CIC (Coordinated Industry...

Tax Court Collection Due Process Standard of Review Upended by the First Circuit

In a decision that could dramatically change collection due process, the First Circuit Court of Appeals held that the standard of review applied to collection due process cases by the Tax Court for more than a decade is incorrect. In Dalton v. Commissioner, No. 11-2217P-01A (1st Cir. June 20, 2012) ...