Megan Brackney was named by Lawline as one of the “Top Women Faculty of 2019” for a CLE program she taught entitled “Tax Procedure: IRS Methods of Obtaining Information From and About Taxpayers.” Lawline noted that the program “has received 500 views and counting since the December 2019 live broadcast.” Lawline,
Drawing on their deep experience representing clients facing some of the most challenging and complex tax controversy matters, Kostelanetz & Fink partners Bryan Skarlatos and Megan Brackney have for years been bringing their expertise into the classroom as adjunct professors at New York University School of Law. This spring, Mr.
By Megan L. Brackney Procedurally Taxing January 8, 2020 The Gifts That Keep on Giving Two young people moved to the U.S. as students. They met in graduate school and married. After graduation, they were offered jobs and were sponsored by their employers so that they could stay in the U.S.
By Megan L. Brackney Procedurally Taxing January 7, 2020 Reasonable Cause For all of the foreign information return penalties, reasonable cause is a defense. See I.R.C. §§ 6038, 6038A(d)(3), 6038D(g), 6039F(c)(2), 6677(d); Treas. Reg. § 1.6038-2(k)(3)(ii). The IRS applies the same standards for reasonable cause for failure to file income tax returns under I.R.C. § 6651 to failure to file foreign
By Megan L. Brackney Procedurally Taxing January 6, 2020 The IRS has been assessing more and more foreign information return penalties on taxpayers. It is difficult to find statistics on this point, as the IRS’s reports on tax penalties lump all “nonreturn” penalties into one category, which includes failure to file Forms
Common errors include neglecting to report all taxable income or valuable deductions and credits Even with the increasingly widespread use of sophisticated tax-preparation software, it’s easy to make costly errors, omissions or both. In the dazzlingly complex world of income taxes, however, amending a return isn’t always as simple as
By Megan L. Brackney Journal of Passthrough Entities September – October 2019 Edition As Treasury and the IRS implement the Tax Cuts and Jobs Act (“TCJA”) of 2017, it is a good time to consider when taxpayers can rely on informal IRS guidance, such as publications, forms, instructions, and frequently asked
NEW YORK CITY, NY (September 12, 2019) – Kostelanetz & Fink is pleased to announce that nine attorneys at the firm, including seven partners, have been selected for inclusion in the 2019 New York Metro “Super Lawyers” list, recognizing the firm’s experience and skill in the areas of Tax, Criminal
By Megan L. Brackney Journal of Passthrough Entities May – June 2019 Edition Under the injunction statutes in the Internal Revenue Code, the U.S. government has broad discretion to seek—and the federal courts to order—the injunction of the preparation of false or fraudulent returns, as well as the aiding and abetting
By: Megan L. Brackney The CPA Journal June 2019 Edition Although some are unaware of the fact, taxpayers can recover fees and costs from the government if the IRS has taken an unreasonable position against them. The IRS may be responsible for fees due to unreasonable positions that it took during
