Articles Posted in IRS representation

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…

California’s proposed billionaire tax has put the California residency audit back in the national spotlight, and made it the single most important issue for wealthy individuals who have recently left the state or are thinking about it. As Proposition 40, the 2026 Billionaire Tax Act, heads toward a statewide vote, the California Franchise Tax Board…

Tax professionals and taxpayers alike have noticed a shift: IRS frivolous return notices (Letter 3176C) are landing on returns that claimed ordinary tax credits, not the tax-protester filings the program was built to catch. If you claimed a credit you believed you were entitled to and received a notice calling your position frivolous, the explanation…

Receiving a frivolous return notice when you filed an ordinary, good-faith tax return is jarring. The IRS uses the word “frivolous” to describe positions it considers baseless — the stuff of tax-protester theories — yet a growing number of taxpayers are getting these letters (IRS Letter 3176C) for returns that were nothing of the sort.…

If you have received IRS Letter 3176C, the notice is telling you the IRS believes your tax return contains a “frivolous” position, and that a $5,000 penalty may follow if you do not respond correctly within 30 days. For many taxpayers, that language is alarming and confusing, especially when the return in question looked entirely…

When the IRS opens an examination of your return, the first practical question is who you should hire to defend it. Most taxpayers default to their CPA — and for many routine examinations, that is the right call. Some hire a tax attorney. A few hire an Enrolled Agent. And a small number ask the…

For years, cryptocurrency holders operated on the assumption that the IRS could not see what was happening on the blockchain. That assumption was always wrong, and it is now demonstrably wrong. Through John Doe summonses served on major exchanges, sophisticated blockchain analytics partnerships, expanded reporting requirements, and a coordinated enforcement initiative that began with Operation…

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…

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…