CPA-San Antonio

By Leo Unzeitig, J.D., CPA-San Antonio Most of us know that IRC 6751(b) requires that revenue agents secure written managerial approval before asserting penalties against taxpayers. This is an important safeguard intended to prevent revenue agents from using penalties as bargaining chips during the audit process. In LakePoint Land II v. Commissioner, T.C. Memo. 2023-111, we learned that at least two IRS agents were complicit in backdating penalty approval forms.

By: Leo Unzeitig, J.D., CPA-San Antonio, and Kenneth Horwitz, J.D., CPA-Dallas Recent court decisions have created a significant, and largely overlooked, opportunity to secure substantial refunds. Based on the mandatory disaster relief provisions in IRC Section 7508A, courts have affirmed that the entire United States was under a federally declared disaster caused by the COVID-19 pandemic from Jan. 20, 2020, to July 10, 2023.