Category Archives: Tax Controversies

Who Will Pay for IRS’s 600+ New Enforcement Personnel?

The IRS recently announced it will hire between 600 and 700 new enforcement personnel.

According to the daily news service Government Executive, in an internal IRS memorandum discussing the hires, Commissioner of Internal Revenue John Koskinen noted: “This is a good development for our tax system. When you look at the IRS overall, every dollar invested in us returns at least $4 to the Treasury. Each enforcement position typically returns almost $10 to the U.S. Treasury for every dollar spent — and in many instances, much more.”

The Commissioner indicated the IRS needs the hires to replace employees lost to attrition and retirement.  He did not, however, specify exactly who will enjoy the civic opportunity to fund IRS’s almost 1,000% expected return on its investment.

Here is the complete article describing the hires in Government Executive:

E. John Wagner, II

Williams Parker Obtains Tax Ruling that TEFRA Does Not Apply to Payroll Tax Audits of Partnerships

During the course of an audit of a partnership for employment tax matters, an issue arose as to whether the tax partnership (which has numerous partners) was subject to the unified partnership audit and litigation provisions of TEFRA (the Tax Equity and Fiscal Responsibility Act of 1982). Representing the partnership, Williams Parker took the position that while the partnership was subject to TEFRA for income tax purposes, it was not subject to TEFRA for employment tax or worker classification matters. Due to the multitude of partners and other factors, being subject to TEFRA would have resulted in the partnership incurring significant expense and headache in trying to comply with the various TEFRA provisions during the course of the audit and any subsequent tax proceedings. Fortunately, the Internal Revenue Service Office of Chief Counsel agreed with Williams Parker in a published ruling, which can be found at the following link: TEFRA Ruling.

Michael J. Wilson

Williams Parker settles $3 Million Tax Court Litigation on Behalf of Client

Williams Parker acted as tax counsel for a client in connection with a $3 million income tax dispute with the Internal Revenue Service. The dispute involved the proper allocation of income among entities in a multi-entity corporate structure where some of the entities were C corporations and others were pass-through entities. Williams Parker partner Mike Wilson handled the Tax Court litigation on behalf of the client, and was able to settle the dispute with the IRS Chief Counsel’s office for $0.00 – a complete victory for the client.

Michael J. Wilson