A View from Meadows Collier

In this episode, Joel Crouch and Matt Roberts examine a series of recent tax cases and enforcement developments highlighting how procedural missteps, aggressive positions, and poor documentation can quickly escalate into substantial penalties and prolonged disputes with the IRS. The discussion explores several notable Tax Court and appellate decisions involving conservation easements, partnership reporting issues, substantiation failures, and penalty challenges, with a focus on how courts are evaluating taxpayer conduct and reasonable cause defenses in today's enforcement environment. Joel and Matt also analyze the practical implications of recent ruling affecting IRS procedure, litigation strategy, and taxpayer rights, including cases that demonstrate the significant consequences of missed deadlines, incomplete records, and flawed transactional planning. Throughout the episode, they offer practical guidance for taxpayers and practitioners navigating audits, appeals, and high-stakes tax controversy matters in an increasingly technical and penalty-driven landscape.

In this episode, Joel Crouch and Matt Roberts walk through a wide-ranging update on recent tax cases and developments shaping the current tax controversy landscape. They begin with the Fifth Circuit's closely watched decision in Sirius Solutions LLLP v. Commissioner, examining the court's rejection of the Tax Court's functional analysis for limited partners and what the ruling means for self-employment tax exposure and audit strategy. They then turn to a series of cautionary tales from the Tax Court and federal courts, including an estate tax case illustrating the risks of late filings and executor liability. The discussion also covers evolving developments in FBAR willfulness following the Second Circuit's Reyes decision, as well as ongoing Seventh Amendment challenges to civil tax penalties. Joel and Matt offer practical takeaways for taxpayers and practitioners alike, highlighting how bad facts, procedural shortcuts, and shifting precedent can dramatically affect penalty exposure, litigation risk, and audit outcomes. 

In this episode, Joel Crouch and Matt Roberts take a deep dive into several recent tax cases shaping today's tax controversy landscape. They begin with Patel, a precedential Tax Court decision addressing captive insurance transactions and the application of accuracy-related penalties for lack of economic substance, including what constitutes adequate disclosure and why the absence of a reasonable cause defense can be so consequential. Joel and Matt then turn to a series of jurisdictional cases following Boechler, examining whether statutory filing deadlines in Tax Court are truly jurisdictional or subject to equitable tolling and what recent circuit court decisions mean for taxpayers who miss those deadlines. The discussion also covers partnership audit timing issues under the former TEFRA regime, as well as emerging Seventh Amendment challenges to civil tax penalties in the wake of recent Supreme Court precedent. This episode offers practical insights into audit strategy, penalty defense, and procedural pitfalls.

In this episode, Mary Wood and Josh Ungerman break down two often-confused provisions in the Internal Revenue Code: Section 183, the hobby loss rules, and Section 469, the passive activity loss rules. They explain how the IRS determines whether an activity is a genuine business or a personal pastime, and why the distinction can mean the difference between deductible losses and permanent disallowance. From the nine factor profit motive test to the material participation standards, Mary and Josh discuss how taxpayers can document intent, track time, and substantiate their activities to withstand IRS scrutiny. They also share practical strategies for grouping activities, maintaining contemporaneous records, and addressing common audit pitfalls. This episode offers real-world guidance for defending profit motive and preserving valuable deductions.

In this episode, Joel Crouch and Matthew Roberts explore all things IRS statutes of limitations - the timeframes that govern how long the IRS has to assess or collect taxes, and how long taxpayers have to file refund claims. They break down the general three-year rule and dive into the many exceptions that can extend or suspend the clock, including issues involving foreign reporting, bankruptcy, and fraud. From assessment and collection to refund claims and protective filings, Joel and Matt  discuss common traps, strategic considerations, and real-world examples that illustrates how timing can make or break a tax case. Whether you're managing an examination, filing an amended return, or weighing an IRS extension request, gain practical insights to help taxpayers and practitioners navigate the ticking clock with confidence.

In this episode, Joel Crouch and Mary Wood explore the IRS's renewed focus on private aircraft audits. They explain why the IRS views airplanes as "low-hanging fruit," how data analytics and FAA records are being used to flag potential abuse, and what documentation is critical for taxpayers to maintain. From navigating the 50% business-use requirement for bonus depreciation to handling personal and entertainment flights under TCJA, they break down the nuances that can make or break deductions. Mr. Crouch and Ms. Wood also share practical strategies for creating a recordkeeping system, addressing mixed-use flights, and preparing for questions that might arise during an IRS exam. Whether you're a business owner, advisor, or practitioner, this episode provides valuable insights into reducing audit risk and protecting the tax benefits of private aircraft ownership.

In this episode, Joel Crouch and Matthew Roberts dive into the IRS appeals process - what it is, how it works, and why it can be a crucial tool for resolving tax disputes. They explore when and how taxpayers can access Appeals after an audit, penalty, or collection action, as well as the advantages of forum's impartial approach. From strategies for preparing persuasive protests to navigating Collection Due Process hearings and avoiding common pitfalls, Mr. Crouch and Mr. Roberts share practical tips to help taxpayer achieve fair outcomes without litigation. Whether you're handling a complex exam issue or seeking penalty relief, this analysis offers guidance on making the most of the IRS Appeals process.

In the latest episode of the Meadows Collier podcast, Mike Villa welcomes Joe Rillotta, the newest partner at Meadows Collier, to discuss his unique career across private practice, the Department of Justice Tax Division, and serving as Counselor to the IRS Commissioner. Mr. Rillotta shares insights from his years as a prosecutor handling criminal tax cases, explains the distinctive DOJ Tax conference process, and reflects on the differences between advising government agencies and counseling individual clients. He also provides perspective on current IRS and DOJ enforcement priorities, including abusive trusts, data analytics, and high-profile investigations like the so-called "tribal tax credits." Whether you're a tax professional, advisor, or client navigating enforcement risks, this episode offers an inside look at government decision-making and what Mr. Rillotta's experience means for his new role at Meadows Collier.

In this episode, Joel Crouch and Matt Roberts break down the sweeping provisions of the One Big Beautiful Bill Act (OBBBA). They explain how the legislation makes key elements of the Tax Cuts and Jobs Act permanent, while introducing new deductions and limitations that affect both individuals and businesses alike. From estate tax exemptions and R&D expensing rules to gambling loss limitations, tip and overtime deductions, and bonus and depreciation incentives, Mr. Crouch and Mr. Roberts highlight both the opportunities and challenges created by the OBBBA. Whether you're advising clients, planning for your own business, or just trying to keep up with the latest in tax reform, this episode provides timely perspectives to help you navigate the impact of the OBBBA.

In this episode, Jeffrey Glassman and Naveid Jahansouz explore the complexities of employment taxes, especially worker classification and IRS audits. They explain the difference between employees and independent contractors, highlighting the consequences of misclassification, and discuss practical strategies to avoid costly IRS reclassification. From proactive strategies, like voluntary settlement programs, to the nuances of Section 530 relief and what to expect if the IRS challenges your classification of works, Mr. Glassman and Mr. Jahansouz share profession perspectives to help companies understand the pros and cons of each type of worker. Whether you're a business owner, advisor, or practitioner, this episode offers practical insights to help navigate employment tax compliance and avoid costly missteps.