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…
Read MoreIn 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…
Read MorePreventing 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…
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