September 2018

Untimely CDP Arguments Worth Consideration


By Eli S. Noff, Esq., CPA, Partner Mary Lundstedt, Esq. The taxpayer in Berkun v. Commissioner1 ultimately raised two collection due process arguments too late for consideration on appeal, but the Eleventh Circuit apparently found them worthy enough to highlight in a published opinion. Although the Eleventh Circuit uses a [...]

Untimely CDP Arguments Worth Consideration2018-12-13T17:52:30+00:00

Coming Out of the Dark of International Tax Avoidance


By: Eli S. Noff, Partner and Peter Palsen Jakarta, Indonesia - 1990 The aroma of my strong Java coffee blended with the smell of the dark teak paneling of the conference room of my client's office. I glanced at my U.S.-citizen client and then back to the two bankers who [...]

Coming Out of the Dark of International Tax Avoidance2018-12-13T17:58:40+00:00

How Do You Challenge a Florida Tax Audit?


The tax audit process in Florida can be a harrowing one. Often times, after the audit is done, you just pay what you owe and move on. But there are times when you might not be satisfied with the results of the tax audit. The tax auditor may be [...]

How Do You Challenge a Florida Tax Audit?2018-12-08T22:01:25+00:00
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