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Author: Lawrence Brown

April 21, 2023


What Are the IRS’ “Listed Transactions?”

Through its rulemaking authority, the Internal Revenue Service (IRS) has identified several types of transactions as “listed transactions.” As the IRS explains, a listed transaction is any transaction that is, “the same as, or substantially similar to, one that the IRS has determined to be a tax avoidance transaction and […]

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March 17, 2023


Why Is IRS CI Investigating You or Your Business?

If you have been contacted by Special Agents from the Internal Revenue Service’s Criminal Investigation division (IRS CI), one of the first questions you need to answer is, “Why?” IRS CI investigates a broad range of both tax-related and non-tax-related offenses, and determining the specific accusations underlying an IRS CI […]

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February 14, 2023


When Does Tax Avoidance Cross the Line to Tax Evasion?

Tax planning is crucial for high-income individuals. While the Internal Revenue Code imposes substantial tax liability for those who are in the one percent, it also provides opportunities for high-income taxpayers to lawfully reduce the amount they owe. The Internal Revenue Service (IRS) refers to this as “tax avoidance,” and […]

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Tax Evasion