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…

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…

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…

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,…

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…

The IRS statute of limitations on tax debt — known inside the agency as the Collection Statute Expiration Date, or CSED — is one of the most misunderstood rules in federal tax collection. In theory, the IRS has ten years from the date of assessment to collect a tax liability. In practice, that clock is…

By Alex Kugelman, Founder and Managing Attorney, Kugelman Law Not all cryptocurrency audits are the same. Understanding the types of cryptocurrency tax audits the IRS conducts — and what typically triggers each — gives crypto investors, traders, miners, and businesses a meaningful head start in evaluating their exposure and their options. A correspondence audit and…