Blog

BBA Centralized Partnership Audit Rules and Bankruptcy

April 3, 2020

In this article Lavar discusses the parallel between bankruptcy and taxes. It appears to be a metaphysical certainty that Congress, when it enacted the new Centralized Partnership Audit Regime ("CPAR") rules contained in 6221 through 6241 of the Internal Revenue Code in 2015, forgot that it had enacted the Bankruptcy Code almost forty years earlier.

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7th Annual Young Tax Lawyers Conference

March 5, 2020

Don’t miss our own Lisa Nelson and Jonathan Amitrano speaking at the 7th Annual Young Tax Lawyers (YTL) Conference held at UCI School of Law on April 17, 2020.  The Law Offices of A. Lavar Taylor is proud to be a Diamond Sponsor for this event.

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A. Lavar Taylor Speaking About Current Developments in Collection Enforcement

January 10, 2020

A. Lavar Taylor will be a panel speaker on the program of “Current Developments in Collection Enforcement” on Friday, January 31, 2020 at the ABA’s Midyear Tax Meeting 2020 in Boca Raton, Florida.

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IRS Commissioner Charles P. Rettig Will Deliver Keynote Address at Second Annual UCI-A. Lavar Taylor Tax Symposium

December 2, 2019

The University of California, Irvine School of Law (UCI Law) is delighted to announce that the Commissioner of the Internal Revenue Service (IRS), Charles P. Rettig, will be the keynote speaker at the Second Annual UCI-A. Lavar Taylor Tax Symposium at noon on February 24, 2020 on tax and artificial Intelligence. The Commissioner will discuss IRS initiatives in this area.

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Are Alleged Alter Egos, Successors in Interest and/or Transferees Entitled to Their Own Collection Due Process Rights Under Sections 6320 And 6330? Part 5

December 10, 2018

Original appeared in Procedurally Taxing

In Part 4 of this series, I discussed the questions of 1) how a putative alter ego/successor in interest/transferee of a taxpayer might pursue litigation in the Tax Court to raise the questions of whether they are entitled to Collection Due Process (“CDP”) rights under sections 6330 and 6320 of the Code, independent of the rights of the original taxpayer who incurred the liability, 2) whether the government can take administrative collection action against a putative alter ego/successor in interest/transferee without first obtaining a District Court judgment or making a separate assessment, and 3) whether the Tax Court has the ability to address issues 1 and 2 above, given that no notice of determination is ever issued by the IRS in these situations.

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