Sarah M. Raben
Subscribe to Sarah M. Raben's PostsSarah M. Raben focuses her practice on private client matters with particular experience in tax controversy. Prior to joining McDermott, she worked for the IRS Office of Chief Counsel. Read Sarah Raben's full bio.
Weekly IRS Roundup May 1 – May 5, 2023
By Sarah M. Raben on May 8, 2023
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 1, 2023 – May 5, 2023. May 1, 2023: The IRS released Internal Revenue Bulletin 2023-18, which highlights the following: Announcement 2023-13: The Office of Professional Responsibility announced recent disciplinary sanctions involving lawyers, certified public...
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Weekly IRS Roundup April 24 – April 28, 2023
By Sarah M. Raben on May 2, 2023
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 24, 2023 – April 28, 2023. April 24, 2023: The IRS released Internal Revenue Bulletin 2023-17, which highlights the following: REG 121709-19: This document provides proposed regulations regarding supervisory approval of penalties. The purpose is...
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IRS Updates Its List of Compliance Campaigns
By Kevin Spencer and Sarah M. Raben on Apr 28, 2023
Posted In IRS Audits, IRS Guidance
The Internal Revenue Service’s (IRS) Large Business and International (LB&I) Division updated its list of Active Campaigns, which includes more than 50 efforts to increase tax compliance. Each campaign identifies the practice area, lead executive, a point of contact and a description or purpose for the campaign. Notable campaigns include the Micro-Captive Insurance Campaign, Virtual...
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Tax Court Tells IRS It Cannot Assess or Collect Certain Tax Penalties
By Daniel J. Bell, Steven Hadjilogiou, Sarah M. Raben and Kevin Spencer on Apr 26, 2023
Posted In Court Procedure Matters, IRS Guidance, Tax Refunds, Trial Courts
On April 3, 2023, the US Tax Court issued its opinion in Farhy v. Commissioner, holding that the Internal Revenue Service (IRS) lacked the statutory authority to both assess tax penalties under Internal Revenue Code (Code) Section 6038(b) and collect said penalties via a levy against the taxpayer. The decision in Farhy is significant because the IRS regularly...
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Weekly IRS Roundup April 17 – April 21, 2023
By Sarah M. Raben on Apr 24, 2023
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 17, 2023 – April 21, 2023. April 17, 2023: The IRS released Internal Revenue Bulletin 2023-16, which highlights the following: Announcement 2023-10: This announcement was issued pursuant to the Ticket to Work and Work Incentives...
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Weekly IRS Roundup April 10 – April 14, 2023
By Sarah M. Raben on Apr 17, 2023
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 10, 2023 – April 14, 2023. April 10, 2023: The IRS released Internal Revenue Bulletin 2023-15, which highlights the following: Revenue Procedure 2023-20: This revenue procedure modifies the effective date of additions to the taxable...
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IRS Proposes New Regulations to Settle Supervisory Approval of Penalties Requirements
By Kevin Spencer and Sarah M. Raben on Apr 14, 2023
Posted In Appellate Courts, Court Procedure Matters, IRS Audits, IRS Guidance, Trial Courts
The Internal Revenue Service (IRS) has proposed regulations to clarify the rules regarding supervisory approval of federal civil tax penalties under IRC Section 6751(b). Since Chai v. Commissioner, there has been a substantial number of cases litigating issues involving supervisory approval of federal civil tax penalties. Back in September, we posted about the US Court of...
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Weekly IRS Roundup April 3 – April 7, 2023
By Sarah M. Raben on Apr 10, 2023
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 3, 2023 – April 7, 2023. April 3, 2023: The IRS released Internal Revenue Bulletin 2023-14, which highlights the following: Notice 2023-25: This notice provides guidance on the corporate bond monthly yield curve, the corresponding...
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Weekly IRS Roundup March 27 – March 31, 2023
By Sarah M. Raben on Apr 3, 2023
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 March 27, 2023 – March 31, 2023. March 27, 2023: The IRS released Internal Revenue Bulletin 2023-13, which highlights the following: Notice 2023-23: This notice provides guidance to financial institutions on reporting required minimum distributions (RMDs)...
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Weekly IRS Roundup March 20 – March 24, 2023
By Sarah M. Raben on Mar 27, 2023
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 March 20, 2023 – March 24, 2023. March 20, 2023: The IRS released Internal Revenue Bulletin 2023-12, which highlights the following: Notice 2023-22: This notice advises state and local housing credit agencies that allocate low-income housing...
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