Tax Controversy Report Blog

Brian is a contributing author on this blog, which reports on the latest developments in all aspects of tax controversy and financial crimes. He writes about criminal tax; domestic and international compliance issues, and civil tax matters before the Internal Revenue Service. He also writes about audits, appeals, collection matters and tax litigation in the U.S. Tax Court, U.S. Court of Federal Claims, U.S. District Courts and U.S. Appellate Courts.

Recent Blog Posts

Taxpayer Assistance and Service Act Title X:  Miscellaneous Provisions

This is the final post in a series of ten client alerts summarizing the key provisions of the Taxpayer Assistance and Service Act, a bipartisan legislative package introduced on February 26, 2026, by Senate Finance Committee Chairman Mike Crapo (R-Idaho) and Ranking Member Ron Wyden (D-Oregon) to improve service and administration at the Internal Revenue Service.  Title X includes several administrative and technical provisions. For a general overview of the legislation, please refer to the Introduction and summaries of Titles I, II, III, IV, V, VI, VII, VIII, and…More

Taxpayer Assistance and Service Act Title IX:  Small Business

This is the ninth in a series of ten client alerts summarizing the key provisions of the Taxpayer Assistance and Service Act, a bipartisan legislative package introduced on February 26, 2026, by Senate Finance Committee Chairman Mike Crapo (R-Idaho) and Ranking Member Ron Wyden (D-Oregon) to improve service and administration at the Internal Revenue Service.  Title IX proposes significant changes in order to reduce compliance burdens for small businesses and independent contractors.  For a general overview of the legislation, please…More

Taxpayer Assistance and Service Act Title VIII: Hostages

This is the eighth in a series of ten client alerts summarizing the key provisions of the Taxpayer Assistance and Service Act (the “TAS Act”), a bipartisan legislative package introduced on February 26, 2026, by Senators Crapo and Wyden to improve service and administration at the Internal Revenue Service (“IRS”).  This alert addresses Title VIII of the proposed legislation, which focuses on Hostages. For a general overview of the legislation, please refer to the Introduction of this series and summaries…More

Taxpayer Assistance and Service Act Title VII: Whistleblowers

This is the seventh in a series of ten client alerts summarizing the key provisions of the Taxpayer Assistance and Service Act (the “TAS Act”), a bipartisan legislative package introduced on February 26, 2026, by Senators Crapo and Wyden to improve service and administration at the Internal Revenue Service (“IRS”).  This alert addresses Title VII of the proposed legislation, which focuses on Whistleblowers. For a general overview of the legislation, please refer to the Introduction of this series and summaries…More

Taxpayer Assistance and Service Act Title VI: IRS Independent Office of Appeals

This is the sixth in a series of ten client alerts summarizing the key provisions of the Taxpayer Assistance and Service Act (the “TAS Act”), a bipartisan legislative package introduced on February 26, 2026, by Senators Crapo and Wyden to improve service and administration at the Internal Revenue Service (“IRS”).  This alert addresses Title VI of the proposed legislation, which focuses on the IRS Independent Office of Appeals. For a general overview of the legislation, please refer to the Introduction…More

Taxpayer Assistance and Service Act Title V: Tax Return Preparers

This article is the fifth in a series analyzing the proposed Taxpayer Assistance and Service Act (the “TAS Act”), bipartisan legislation introduced by Senators Crapo and Wyden to improve service and administration at the Internal Revenue Service (“IRS”).  Our prior entries in the series are Title I (Tax Administration), Title II (American Citizens Abroad), Title III (Judicial Review), and Title IV (Taxpayer Advocate). This article examines the provisions of Title V of the TAS Act, titled “Tax Return Preparers.”  Title V…More

Taxpayer Assistance and Service Act Title IV: Office of the Taxpayer Advocate

This is the fourth in a series of ten client alerts summarizing the key provisions of the Taxpayer Assistance and Service Act (the “TAS Act”), a bipartisan legislative package introduced on February 26, 2026, by Senators Crapo and Wyden to improve service and administration at the Internal Revenue Service (“IRS”).  This alert addresses Title IV of the proposed legislation, which focuses on the Office of the Taxpayer Advocate. For a general overview of the legislation, please refer to the Introduction…More

The Taxpayer Assistance and Service Act: Title III: Judicial Review

This article is the third in a series analyzing the proposed Taxpayer Assistance and Service Act (the “TAS Act”), bipartisan legislation introduced by Senators Crapo and Wyden to improve service and administration at the Internal Revenue Service (“IRS”).  Our introduction to the series is here, our discussion of Title I is here, and our discussion of Title II is here. This article examines the provisions of Title III of the TAS Act, titled “Judicial Review.”  Title III expands the jurisdiction and…More

The Taxpayer Assistance and Service Act: Title II: American Citizens Abroad

This article is the second in a series analyzing the proposed Taxpayer Assistance and Service Act (the “TAS Act”), bipartisan legislation introduced by Senators Crapo and Wyden to improve service and administration at the Internal Revenue Service (“IRS”).  Our introduction to the series is here, and our discussion of Title I is here. This article examines the provisions of Title II of the TAS Act, titled “American Citizens Abroad.” Title II focuses on the compliance burdens facing U.S. citizens living outside…More

Taxpayer Assistance and Service Act Title I: Tax Administration and Customer Service

This article is the first in a series of articles analyzing the Taxpayer Assistance and Service Act (the “TAS Act”), bipartisan legislation introduced by Senators Crapo and Wyden to improve service and administration at the Internal Revenue Service (“IRS”). Our introduction to the series can be found here. This article examines the most important provisions of Title I of the TAS Act, titled “Tax Administration and Customer Service.” Title I focuses on modernizing IRS operations and responds to longstanding concerns about…More