The IRS recently announced it will hire between 600 and 700 new enforcement personnel. According to the daily news service Government Executive, in an internal IRS memorandum discussing the hires, Commissioner of Internal Revenue John Koskinen noted: “This is a good development for our tax system. When you look at…
During the course of an audit of a partnership for employment tax matters, an issue arose as to whether the tax partnership (which has numerous partners) was subject to the unified partnership audit and litigation provisions of TEFRA (the Tax Equity and Fiscal Responsibility Act of 1982). Representing the partnership,…
Williams Parker acted as tax counsel for a client in connection with a $3 million income tax dispute with the Internal Revenue Service. The dispute involved the proper allocation of income among entities in a multi-entity corporate structure where some of the entities were C corporations and others were pass-through…