Claiming the Qualified Small Business Stock exclusion on your tax return is not the finish line. It is the moment the position becomes reviewable. A QSBS audit is the IRS’s examination of whether a Section 1202 exclusion was actually earned, and because these claims routinely shelter seven- and eight-figure gains, they draw serious attention. When…
Continue reading ›The 2025 QSBS changes are the most significant expansion of the Qualified Small Business Stock rules in more than a decade. Enacted as part of the One Big Beautiful Bill Act, the new law rewrites key parts of Section 1202 for stock acquired after July 4, 2025. It shortens the wait for a partial exclusion,…
Continue reading ›Qualified Small Business Stock (QSBS) is one of the most powerful tax benefits available to founders, early employees, and investors. Under Section 1202 of the Internal Revenue Code, a taxpayer who holds qualifying stock in a small C corporation can exclude a large portion, and in many cases all, of the capital gain when the…
Continue reading ›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…
Continue reading ›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…
Continue reading ›The Form 3520 penalty is one of the harshest in the Internal Revenue Code. A U.S. person who receives a gift or inheritance from a foreign person exceeding the annual reporting thresholds and fails to timely file Form 3520 faces a penalty of up to 25% of the gift or inheritance — even though the…
Continue reading ›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…
Continue reading ›If you received an IRS crypto letter 6173, Letter 6174, or Letter 6174-A, the IRS believes you may have engaged in one or more cryptocurrency transactions that were not properly reported. These letters are not random. They are the product of targeted enforcement built on data the IRS obtained through John Doe summonses against Coinbase,…
Continue reading ›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…
Continue reading ›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…
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