by Tyler B. Korn, Esq. | Jul 29, 2010 | Articles
Under Section 7430 of the Internal Revenue Code, the prevailing party in any civil tax proceeding brought by or against the United States is permitted a discretionary award of litigation costs, including attorneys’ fees. A “prevailing party” is defined as a...
by Tyler B. Korn, Esq. | Jul 29, 2010 | Articles
The Korn Law Firm, P.L. / Tel (239) 354-4300 One of the primary reasons why computation of a partner’s interest in a partnership and its assets often confuses partners and their advisers alike is that two different, contemporaneously operating measurements exist to...
by Tyler B. Korn, Esq. | Jul 29, 2010 | Articles
The Korn Law Firm, P.L. / Tel (239) 354-4300 In handling civil and criminal tax cases, I am often asked whether, and to what extent, an accountant-client confidentiality or work-product privilege exists. The applicability of such a privilege is often of pivotal...
by Tyler B. Korn, Esq. | Jul 29, 2010 | Articles
The Korn Law Firm, P.L. / Tel (239) 354-4300 It is not an uncommon occurrence for taxpayers, even those well-experienced with federal tax audits, to become discomposed upon receipt of an Internal Revenue Service summons. Understandably, a summons by the IRS tends to...
by Tyler B. Korn, Esq. | Jul 29, 2010 | Articles
Provision for a “Minimum Gain Chargeback” exists in nearly every partnership agreement and limited liability company operating agreement. Few people, however, actually understand the need for such provision or its function, and few attorneys – even...
by Tyler B. Korn, Esq. | Jul 29, 2010 | Articles
Under normal assessment procedures, the Internal Revenue Service is prohibited from assessing and collecting a tax deficiency from a taxpayer until the taxpayer has been sent a valid, statutory notice of deficiency and has been given a 90-day (or, if applicable, a...
