A View from Meadows Collier

In this episode, Joel Crouch and Matt Roberts take a deep dive into several recent tax cases shaping today's tax controversy landscape. They begin with Patel, a precedential Tax Court decision addressing captive insurance transactions and the application of accuracy-related penalties for lack of economic substance, including what constitutes adequate disclosure and why the absence of a reasonable cause defense can be so conseq...

In this episode, Mary Wood and Josh Ungerman break down two often-confused provisions in the Internal Revenue Code: Section 183, the hobby loss rules, and Section 469, the passive activity loss rules. They explain how the IRS determines whether an activity is a genuine business or a personal pastime, and why the distinction can mean the difference between deductible losses and permanent disallowance. From the nine factor profit mot...

In this episode, Joel Crouch and Matthew Roberts explore all things IRS statutes of limitations - the timeframes that govern how long the IRS has to assess or collect taxes, and how long taxpayers have to file refund claims. They break down the general three-year rule and dive into the many exceptions that can extend or suspend the clock, including issues involving foreign reporting, bankruptcy, and fraud. From assessment and colle...

In this episode, Joel Crouch and Mary Wood explore the IRS's renewed focus on private aircraft audits. They explain why the IRS views airplanes as "low-hanging fruit," how data analytics and FAA records are being used to flag potential abuse, and what documentation is critical for taxpayers to maintain. From navigating the 50% business-use requirement for bonus depreciation to handling personal and entertainment flig...

In this episode, Joel Crouch and Matthew Roberts dive into the IRS appeals process - what it is, how it works, and why it can be a crucial tool for resolving tax disputes. They explore when and how taxpayers can access Appeals after an audit, penalty, or collection action, as well as the advantages of forum's impartial approach. From strategies for preparing persuasive protests to navigating Collection Due Process hearings and...

In the latest episode of the Meadows Collier podcast, Mike Villa welcomes Joe Rillotta, the newest partner at Meadows Collier, to discuss his unique career across private practice, the Department of Justice Tax Division, and serving as Counselor to the IRS Commissioner. Mr. Rillotta shares insights from his years as a prosecutor handling criminal tax cases, explains the distinctive DOJ Tax conference process, and reflects on the di...

In this episode, Joel Crouch and Matt Roberts break down the sweeping provisions of the One Big Beautiful Bill Act (OBBBA). They explain how the legislation makes key elements of the Tax Cuts and Jobs Act permanent, while introducing new deductions and limitations that affect both individuals and businesses alike. From estate tax exemptions and R&D expensing rules to gambling loss limitations, tip and overtime deductions, and b...

In this episode, Jeffrey Glassman and Naveid Jahansouz explore the complexities of employment taxes, especially worker classification and IRS audits. They explain the difference between employees and independent contractors, highlighting the consequences of misclassification, and discuss practical strategies to avoid costly IRS reclassification. From proactive strategies, like voluntary settlement programs, to the nuances of Sectio...

In this episode, Mike Villa and Damon Rowe explore the IRS's "Dirty Dozen" list of tax scams and schemes, with a unique perspective from Mr. Rowe's 20 years of experience as an IRS criminal investor. They delve into how phishing attacks, misleading social media tax advice, and abusive credit claims can trigger criminal investigations and what practitioners need to know to spot these red flags. Whether you'r...

In this episode, Joel Crouch and Kristen Cox walk through the key legal and practical steps to take prior to selling a company, from the importance of keeping company records in order to the importance of getting legal counsel involved early. Building off of their blog post "15 Things You Should Know About Selling Your Business," Mr. Crouch and Ms. Cox delve into the step by step process of selling a business and how to m...

In this episode, Joel Crouch and Matthew Roberts delve into the ever-expanding world of IRS penalties and how to defend yourself against them. They walk through the categories, thresholds, and abatement options taxpayers need to understand, while also exploring why cases such as Boyle and Huang matter, especially for those relying on software or professionals. If you're trying to understand and minimize your possibilities of p...

In this episode, Joel Crouch and Brian Spiegel break down IRS examinations of gift and estate tax returns, sharing insights of all topics relating to Form 709 and 706 filing. They delve into the IRS's handling of these audits and their triggers, from flawed appraisals to inconsistent documentation, even poorly disclosed transactions. Whether you're preparing returns or responding to an audit, this episode offers essential...

In this episode, Joel Crouch and Annie McGinnis discuss the basic types of business entities: sole proprietorships, partnerships, LLCs, and corporations. They examine the advantages and disadvantages of each entity type, focusing on how liability protections, tax classifications, and long-term objectives influence the best choice for your business. It's essential to consider ownership, structure, and succession plans from day ...

In this episode, Joel Crouch and Nick Pegelow explore the modern landscape of IRS partnership audits under the Bipartisan Budget Act (BBA) rules. They discuss how and why the IRS shifted the audit process, the all-powerful role of the partnership representative, and the importance of making the right elections—like opting out or pushing out adjustments. Whether you’re a partner in a small business or part of a complex investment st...

In this episode of the Meadows Collier Podcast, attorneys Joel Crouch and Jeff Glassman dive deep into the world of tax litigation, offering a candid and practical look at the three main forums where tax disputes play out: U.S. Tax Court, U.S. District Court, and the U.S. Court of Federal Claims.

Whether you're facing a stalled refund claim, an unresolved audit, or weighing your litigation options, Joel and Jeff break...

In this episode, Joel Crouch and Matt Roberts break down recent developments in tax law and IRS procedure that every tax professional and taxpayer should know. From the Murphy case's surprising taxpayer win to a criminal defendant who beat the IRS pro se, Joel and Matt explore fascinating case law, new IRS FAQs on ERC claims, fraud penalty jury trial arguments, FOIA bottlenecks, and a cautionary tale from the conservation ease...

In this episode of the Meadows Collier podcast, Jana Simons joins Joel Crouch to discuss asset protection. They discuss the ins and outs of asset protection in Texas—from exempt assets like homesteads and retirement accounts to strategic planning tools like irrevocable trusts and LLCs. Whether you're a CPA, financial advisor, estate planner, or simply someone looking to protect your hard-earned assets, this conversation will l...

The IRS is undergoing significant workforce reductions, with thousands of employees leaving through layoffs, buyouts, and attrition. While some may welcome the idea of a smaller IRS, tax professionals should prepare for longer delays in audits, appeals, refund claims, and voluntary disclosure cases. In this episode of the Meadows Collier Podcast, Joel Crouch and Matt Roberts discuss how these staffing cuts will impact tax enforceme...