About this episode
In this episode, Joel Crouch and Matt Roberts examine a series of recent tax cases and enforcement developments highlighting how procedural missteps, aggressive positions, and poor documentation can quickly escalate into substantial penalties and prolonged disputes with the IRS. The discussion explores several notable Tax Court and appellate decisions involving conservation easements, partnership reporting issues, substantiation failures, and penalty challenges, with a focus on how courts are evaluating taxpayer conduct and reasonable cause defenses in today's enforcement environment. Joel and Matt also analyze the practical implications of recent ruling affecting IRS procedure, litigation strategy, and taxpayer rights, including cases that demonstrate the significant consequences of missed deadlines, incomplete records, and flawed transactional planning. Throughout the episode, they offer practical guidance for taxpayers and practitioners navigating audits, appeals, and high-stakes tax controversy matters in an increasingly technical and penalty-driven landscape.
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