Edward L. Froelich
Subscribe to Edward L. Froelich's PostsEdward L. Froelich represents domestic and foreign public corporations, privately held companies, partnerships, trusts and individuals across the spectrum of federal tax controversies, including audits, trials and appeals. Ed’s clients include businesses, business owners and investors with operations and interests in the financial services, technology, real estate, healthcare and other industries. Read Edward Froelich's full bio.
IRS Strengthens Its Large Partnership Audit Teams
By Edward L. Froelich on Sep 26, 2023
Posted In IRS Audits, IRS Guidance
Back in October 2021, the Internal Revenue Service’s (IRS) Large Business and International (LB&I) division announced the Large Partnership Compliance (LPC) program. This new audit program adopted features of the Large Corporate Compliance (LCC) program, such as its audit selection method. Similar to the LCC’s audit selection process, the LPC’s audit selection process has two...
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Can the Government Sue for Tax Debts Outside Internal Revenue Code Procedures?
By Kevin Spencer, Edward L. Froelich and Evan Walters on Jul 21, 2023
Posted In Appellate Courts, Court Procedure Matters, Trial Courts
On June 1, 2023, in United States v. Liberty Global, Inc., the US District Court for the District of Colorado held that the US Department of Justice (DOJ) can assert and seek judgment for federal income tax deficiencies using a common law right of action, bypassing the usual statutory tax deficiency procedures outlined in the Internal...
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Tax Court Says Pollution Control Systems Are Not Pilot Models, Rejects Tax Research Credits
By Kevin Spencer and Edward L. Froelich on Jul 14, 2023
Posted In Court Procedure Matters, Trial Courts
On July 6, 2023, the US Tax Court issued its decision in Betz v. Commissioner, T.C. Memo. 2023-84. Betz considers the application of the pilot model supply rule to expenses incurred by a designer (CPI[1]) of made-to-order air pollution control systems called oxidizers. At issue was approximately $500,000 of research and development tax credits pursuant...
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The Government Flexes Its Summons Muscles
By Edward L. Froelich on May 26, 2023
Posted In IRS Guidance
Two recent decisions confirmed the broad administrative summons authority of the Internal Revenue Service (IRS). In the first, the US Supreme Court resolved a circuit conflict regarding notice requirements for third-party IRS summonses. In the second, the US Court of Appeals for the Third Circuit confirmed the primacy of the Internal Revenue Code (IRC) over...
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