Articles Posted in Tax Controversy

Kugelman Law attorney Otto Bosch was quoted in a Tax Notes article published May 26, 2026 — “More Scrutiny of Deferred Legal Fee Structures Could Be Coming” by Lauren Loricchio — providing the insider perspective on why the gap between an IRS audit campaign announcement and active enforcement is routine, what is happening inside IRS…

If you have received an IRS audit notice — or you are worried one might be coming — one of the first questions worth answering is who, exactly, will be examining your return. The answer matters more than most taxpayers realize. The IRS is not a single, undifferentiated organization. Examinations are conducted by specific employees…

An IRS CP2000 notice response is one of the most time-sensitive tasks a taxpayer will ever face. The CP2000 — often called an “underreporter notice” — arrives when the IRS believes the income, payments, credits, or deductions you reported on your tax return do not match what third parties reported about you. You have a…

A California residency audit is one of the most factually invasive and financially consequential examinations a taxpayer can face. The Franchise Tax Board (FTB) has become aggressive in auditing high-income residents who claim they moved — to Texas, Nevada, Florida, Washington, Tennessee, Wyoming, or anywhere else without a state income tax — and it has…

The recent federal decision in Kwong v. United States may give millions of taxpayers a path to recover IRS penalties and interest assessed during the COVID-19 pandemic. If you, your business, or your trust paid Failure-to-File, Failure-to-Pay, or related interest on a tax obligation due between January 20, 2020 and July 10, 2023, the Kwong…

Most taxpayers who receive an IRS audit notice make the same first call: their CPA. A few call a tax attorney. Almost none think to ask a more useful question — does the firm I’m hiring have anyone on the team who has actually sat on the other side of the audit table? A former…