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Matt is the editor of and a contributor to firm's Tax Controversy & Financial Crimes Report blog, which reports on the latest developments in all aspects of tax controversy matters and incorporates coverage of efforts to combat financial crimes.

Matt contributes to the firm's In The Weeds blog, which explores developments in cannabis law and business.

Scroll down to see Matt's most recent posts.

Recent Blog Posts

  • Tax Court Cancels All Trial Sessions Through June 2020 The United States Tax Court issued a press release today announcing that more trial sessions have been cancelled in light of the COVID-19 pandemic.  All trial sessions through the end of June 2020 have now been cancelled.  The Tax Court had previously cancelled trial sessions scheduled for March and April. In addition, the Tax Court building in Washington, D.C. remains closed, and all Tax Court personnel are working remotely.  The Court’s electronic filing system remains operational, and the Court continues... More
  • IRS Releases More Details Regarding Extension of Tax Day to July 15, 2020 As a follow-up to our prior post, the Treasury Department and the Internal Revenue Service have released additional details regarding the extension of the federal income tax filing due date from April 15, 2020, to July 15, 2020. Taxpayers can now defer federal income tax payments due on April 15 to July 15, without penalties and interest, regardless of the amount owed. This deferment applies to all taxpayers, including individuals, trusts and estates, corporations and other non-corporate tax filers as well as... More
  • Pennsylvania Extends Personal Income Tax Return Filing Deadline to July 15, 2020 Following the lead of the Internal Revenue Service, the Pennsylvania Department of Revenue announced yesterday that the deadline for taxpayers to file their 2019 Pennsylvania personal income tax returns is extended to July 15, 2020. This means taxpayers will have an additional 90 days to file from the original deadline of April 15. The Department of Revenue will also waive penalties and interest on 2019 personal income tax payments through the new deadline of July 15, 2020. This extension applies... More
  • Treasury Secretary Announces Federal Tax Filing Deadline Extended to July 15 Due to COVID-19 Treasury Secretary Steven Mnuchin announced on Twitter this morning that the April 15 tax filing deadline has been extended to July 15 due to the health crisis caused by the coronavirus outbreak.   All taxpayers (both individuals and businesses) will have extra time to file and pay their taxes without being subject to penalties and interest. Earlier this week, Treasury announced that tax payments could be deferred until July 15, 2020, without interest or penalty, but that the April 15 deadline would... More
  • Tax Court Cancels March 2020 Trial Sessions Due to Coronavirus The United States Tax Court announced today that in light of the growing threat posed by the coronavirus, it was cancelling the following upcoming trial sessions: March 16, 2020:  Hartford, CT; Philadelphia, PA; and San Francisco, CA  March 17, 2020:  Provo, UT  March 23, 2020:  Boston, MA; Los Angeles, CA; Milwaukee, WI; Pittsburgh, PA; and San Antonio, TX  March 30, 2020:  Chicago, IL; Dallas, TX; Detroit, MI; Los Angeles, CA; New York, NY; and Philadelphia, PA The press release further stated that “[i]n keeping with... More
  • Garden State “Zapper” Users Beware: New Jersey Announces Crackdown on Revenue Suppression Programs Earlier this week, New Jersey Governor Philip Murphy announced his proposed budget for fiscal year 2021.  Buried in the dense text of the 94-page document (at page 37) were several tax enforcement provisions of note.  The budget reveals that the state’s Division of Taxation is implementing new auditing and enforcement measures estimated to yield $40.0 million in addition revenue.  In particular, the state plans to implement enforcement measures to stop “revenue suppression software schemes.” Commonly called “zappers,” revenue suppression programs run... More
  • Chief Judge Foley Re-Elected Chief Judge of the United States Tax Court The United States Tax Court announced earlier this week that Chief Judge Maurice B. Foley has been re-elected and will serve another two-year term beginning June 1, 2020.  His current term as Chief Judge expires May 31, 2020.  The biennial election took place on February 21, 2020, in accordance with statutory requirements. Chief Judge Foley’s biography follows: Chief Judge Foley was appointed to the United States Tax Court by President William J. Clinton. He was reappointed by President Barack Obama and sworn... More
  • Erin M. Collins Appointed National Taxpayer Advocate Today the Treasury Department and Internal Revenue Service announced that Erin M. Collins has been appointed National Taxpayer Advocate.   Collins succeeds Nina E. Olson, who served as the as National Taxpayer Advocate from 2001 until her retirement last summer.   The full text of the press release follows: Washington – Today, the U.S. Treasury Department and Internal Revenue Service (IRS) announced the appointment of Erin M. Collins to serve as the National Taxpayer Advocate (NTA). “Erin Collins will be an outstanding voice for American... More
  • IRS Continues Pressure on Syndicated Conservation Easements The Internal Revenue Service is urging taxpayers involved in syndicated conservation easement transactions to consult with their tax advisors following a recent U.S. Tax Court decision. The IRS also plans to continue aggressive enforcement efforts in this area. In late 2016, the Internal Revenue Service designated certain syndicated conservation easement arrangements as “listed transactions” in Notice 2017-10 (PDF). On December 13, 2019, the U.S. Tax Court entered its first decision on a syndicated conservation easement transaction. In TOT Property Holdings, LLC v.... More
  • IRS Steps Up Scrutiny of Micro-Captive Insurance Transactions The Internal Revenue Service has announced an overwhelming acceptance rate for a time-limited settlement offer made to certain taxpayers under audit who participated in abusive micro-captive insurance transactions. Nearly 80% of taxpayers who received offer letters elected to accept the settlement terms. In addition, the IRS is establishing 12 new examination teams that are expected to open audits related to thousands of taxpayers in coming months. Abusive micro-captives have been a concern to the IRS for several years. The transactions have... More
  • Treasury Department Data Shows Continuing Increase in Availability of Marijuana Banking The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has released updated quarterly statistics showing a continuing increase in the number of depository institutions that actively bank U.S. marijuana businesses. As of March 31, 2018, a total of 411 banks and credit unions provided services to marijuana-related businesses, up from 365 one year ago. FinCEN’s data reflects a slight decrease following the Attorney General’s announcement in January 2018 that he was rescinding the Cole Memorandum, but the numbers quickly went back... More
  • More on Status of FinCEN’s Marijuana Banking Guidance As a follow-up to yesterday’s post regarding the status of FinCEN’s 2014 marijuana banking guidance in light of the Attorney General’s policy reversal on marijuana enforcement at the federal level, we have received written confirmation from FinCEN that its 2014 guidance remains in place.  In response to our inquiries, FinCEN provided us with the following statement: “The SAR reporting structure laid out in the February 14, 2014 guidance remains in place.  FinCEN will continue to work closely with law enforcement and the... More
  • FinCEN Confirms Marijuana Banking Guidance Remains in Place Despite DOJ Policy Reversal Reuters is reporting today that the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) was caught off guard by Attorney General Jeff Sessions’ announcement last week that the Justice Department was reversing its policy regarding enforcement of federal marijuana laws.  A FinCEN spokesman said in a statement that his agency’s prior pronouncement regarding marijuana banking nevertheless “remains in place,”  referring to guidance issued in February 2014 to clarify Bank Secrecy Act expectations for financial institutions seeking to provide services to marijuana-related businesses.  That... More
  • Federal Data Shows More Banks Are Serving Marijuana Businesses The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has released updated statistics showing a steady increase in the number of depository institutions that actively bank U.S. marijuana businesses. As of September 30, 2017, a total of 400 banks and credit unions provided services to marijuana-related businesses, up from 334 as of December 31, 2016. FinCEN’s data is based upon Suspicious Activity Reports (SARs) required to be filed by financial institutions on activity involving a marijuana-related business. In guidance issued in February... More