Taxpayers often use entities characterized as partnerships for federal income tax purposes to conduct their business activities. In addition to offering limited liability (e.g., limited liability ...

Partnerships are not subject to income tax at the entity level. Instead, they operate as pass-through entities, meaning the ...

In tax controversy and litigation matters, sometimes procedure trumps the merits. The statute of limitations is a great example. Even if the taxpayer made a mistake on a prior year return, the IRS ...