A View from Meadows Collier

In this episode, Joel Crouch and Matt Roberts examine a series of recent tax cases and enforcement developments highlighting how procedural missteps, aggressive positions, and poor documentation can quickly escalate into substantial penalties and prolonged disputes with the IRS. The discussion explores several notable Tax Court and appellate decisions involving conservation easements, partnership...

In this episode, Joel Crouch and Matt Roberts walk through a wide-ranging update on recent tax cases and developments shaping the current tax controversy landscape. They begin with the Fifth Circuit's closely watched decision in Sirius Solutions LLLP v. Commissioner , examining the court's rejection of the Tax Court's functional analysis for limited partners and what the ruling mean...

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 reason...

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 disallowan...

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, a...

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 handl...

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...

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 confere...

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,...

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...

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...

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...

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 a...

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 a...

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, struct...

In this episode of the Meadows Collier Podcast, Joel Crouch welcomes Stephanie Grissom to explore the basics of estate planning in Texas. They break down why estate planning isn’t just for the wealthy, covering essential topics like wills, trusts, powers of attorney, and directives to physicians. Learn how proper planning can simplify the process for your loved ones, protect your assets, and ensur...

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 op...

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 cautio...

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-earn...

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 staf...

In this episode of the Meadows Collier Podcast, attorneys Joel Crouch and Naveid Jahansouz provide an in-depth analysis of significant recent developments in tax law and IRS operations. They discuss the ripple effects of IRS staffing challenges, including hiring freezes, buyouts, and leadership departures, and what these changes mean for taxpayers and tax professionals. The episode also covers key...

Join Joel Crouch, Mary Wood, and Jeff Glassman as they discuss what’s ahead for IRS enforcement in 2025. From cutting-edge technology and AI to changes in cryptocurrency reporting and high-net-worth audits, the team shares insights from the December 2024 ABA Tax Section Tax Fraud and Tax Controversy Conference in Las Vegas. This episode also covers key tips for audit preparedness, updates on the E...

In this episode of our podcast, you will discover the latest trends in IRS criminal tax investigations, cryptocurrency compliance and voluntary disclosure programs with Joel Crouch and Mike Villa. This podcast will discuss some of the presentation highlights from the December 2024 American Bar Association (ABA) Criminal Tax Fraud Conference, such as funding, data analytics and areas of priority fo...

In this episode of our podcast, A View from Meadows Collier , we are excited to share a special replay of the December 3, 2024 webinar titled, "Divisive Corporate Reorganizations: Threading the Eye of the I.R.C. § 355 Needle," featuring Firm Partner, Stephen A. Beck. In general, the distribution of appreciated assets from a corporation results in income tax liability to both the distribu...

In this episode, firm lawyers Joel Crouch and Naveid Jahansouz delve into key recent developments in the tax landscape. They discuss noteworthy IRS procedural changes, including the revised penalty assessments for late-filed foreign gift forms, offering taxpayers more leniency with reasonable cause statements. They explore significant court cases like Ruby Tang v. Commissioner , where an IRS emplo...