Firm Insights
This morning, the Supreme Court issued what lawyers correctly regard as a taxpayer-friendly opinion in the case of Bittner v. United States. In that case, by a vote of 5-4, the Court held the maximum penalty that the Government can impose upon a person who nonwillfully fails to file FinCEN Form 114, “Report of Foreign…
In many cases, clients (even the ones who win) wish that they had found an alternative to litigation. I have concluded that the best and most cost-effective way to avoid litigation is EARLY mediation. I implore you to seek a serious structured effort early to resolve the dispute through mediation before legal bills and emotional…
Preventing a late or invalid S corporation election or termination is a high priority for S corporations, their owners, and their advisors. It requires relentless attention to detail because the very existence of an S corporation involves a proverbial minefield of traps for the unwary. Subchapter S (Internal Revenue Code §§ 1361-1379) is filled with…