Kevin Spencer
Subscribe to Kevin Spencer's PostsKevin Spencer focuses his practice on tax controversy issues. Kevin represents clients in complicated tax disputes in court and before the Internal Revenue Service (IRS) at the IRS Appeals and Examination divisions. In addition to his tax controversy practice, Kevin has broad experience advising clients on various tax issues, including tax accounting, employment and reasonable compensation, civil and criminal tax penalties, IRS procedures, reportable transactions and tax shelters, renewable energy, state and local tax, and private client matters. After earning his Master of Tax degree, Kevin had the privilege to clerk for the Honorable Robert P. Ruwe on the US Tax Court. Read Kevin Spencer's full bio.
Supreme Court Rules Against Taxpayers in IRC Section 965 Case
By Kevin Spencer, Evan Walters and Samuel J. Preston on Jun 21, 2024
Posted In Court Procedure Matters, Trial Courts
On June 20, 2024, the Supreme Court of the United States issued a 7-2 opinion in Moore v. United States, 602 U.S. __ (2024), ruling in favor of the Internal Revenue Service (IRS). Moore concerned whether US Congress and the IRS could tax US shareholders of controlled foreign corporations (CFCs) on those corporations’ earnings even...
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Weekly IRS Roundup June 3 – June 7, 2024
By Kevin Spencer, Evan Walters and Sama Kaseer on Jun 13, 2024
Posted In IRS Guidance, Tax Reform, Tax Refunds
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 3, 2024 – June 7, 2024. June 3, 2024: The IRS released Internal Revenue Bulletin 2024-23, which includes Revenue Procedure 2024-23. The revenue procedure provides an updated list of tax accounting method changes for which...
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Weekly IRS Roundup May 27 – May 31, 2024
By Kevin Spencer, Evan Walters and Sama Kaseer on Jun 6, 2024
Posted In IRS Guidance, Tax Reform, Tax Refunds
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 27, 2024 – May 31, 2024. May 28, 2024: The IRS released Internal Revenue Bulletin 2024-22, which includes the following: Revenue Procedure 2024-25, which provides the inflation-adjusted limits related to health savings accounts and high...
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Weekly IRS Roundup May 20 – May 24, 2024
By Kevin Spencer, Evan Walters and Sama Kaseer on May 31, 2024
Posted In IRS Guidance, Tax Reform, Tax Refunds
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 20, 2024 – May 24, 2024. May 20, 2024: The IRS released Internal Revenue Bulletin 2024-21, which includes the following: Treasury Decision 9992, which includes final regulations on the standards under which a qualified investment...
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Weekly IRS Roundup May 13 – May 17, 2024
By Kevin Spencer, Evan Walters and Sama Kaseer on May 24, 2024
Posted In IRS Guidance, Tax Reform, Tax Refunds
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 13, 2024 – May 17, 2024. May 13, 2024: The IRS released Internal Revenue Bulletin 2024-20, which includes proposed regulations concerning the excise tax on stock buybacks under § 4501 of the Internal Revenue Code...
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IRC Section 280E Will No Longer Apply if Marijuana Is Rescheduled
By Kevin Spencer and Samuel J. Preston on May 21, 2024
Posted In Tax Refunds
On May 16, 2024, the US Department of Justice submitted a Notice of Proposed Rulemaking (NPRM) to reschedule marijuana from Schedule I to Schedule III within the Controlled Substances Act. As the NPRM recognizes, this action would have a significant economic impact on a substantial number of businesses – specifically, medical and recreational marijuana dispensaries...
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Weekly IRS Roundup May 6 – May 10, 2024
By Kevin Spencer, Evan Walters and Sama Kaseer on May 16, 2024
Posted In IRS Guidance, Tax Reform
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 6, 2024 – May 10, 2024. May 6, 2024: The IRS released Internal Revenue Bulletin 2024-19, which includes the following: Revenue Ruling 2024-09, which provides the May 2024 applicable federal rates. Notice 2024-35, which provides...
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Understanding the IRC’s Excessive Refund Claim Penalty
By Kevin Spencer, Edward L. Froelich and Samuel J. Preston on May 8, 2024
Posted In Court Procedure Matters, IRS Audits, Tax Refunds, Trial Courts
Recently, the Internal Revenue Service (IRS) has been asserting the Internal Revenue Code Section 6676 penalty much more frequently in examinations and in court. For example, in 2023, a government counterclaim in the US District Court for the Middle District of Georgia sought to recover Section 6676 penalties in Townley v. United States. And, internal IRS guidance requires examiners to consider...
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Weekly IRS Roundup April 29 – May 3, 2024
By Kevin Spencer, Evan Walters and Jeremy Kass on May 7, 2024
Posted In IRS Guidance, Tax Reform
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 29, 2024 – May 3, 2024. April 29, 2024: The IRS released Internal Revenue Bulletin 2024-18, which includes the following: Notice 2024-33, which provides a limited waiver of the addition to tax under Section 6655...
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Weekly IRS Roundup April 22 – April 26, 2024
By Kevin Spencer, Evan Walters and Jeremy Kass on May 2, 2024
Posted In IRS Guidance, Tax Reform, Tax Refunds
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 22, 2024 – April 26, 2024. April 22, 2024: The IRS released Internal Revenue Bulletin 2024-17, which includes the following: Proposed regulations, which would facilitate the transfer of tax return information to the US Census...
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