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When IRS Appeals Rebuilds the Case: ERC, R&D, and the Unknown Documents in PAM
A taxpayer can produce thousands of pages and still reach Appeals with a thin file. Here is why missing IRS file custody changes the hazards—and what PAM should do.

Heath Vo, JD, CPA
Sep 137 min read


Haven’t Filed Taxes in Years? The IRS Is Prioritizing Nonfilers—Act Now.
TIGTA found thousands of high-priority nonfiler cases stalled—but the IRS is moving them forward. Here is why waiting can turn return preparation into an expensive tax controversy.

Heath Vo, JD, CPA
Sep 86 min read
From Bob Jones to SFFA: When an IRS “Clarification” Becomes a New §501(c)(3) Enforcement Standard
The IRS calls its private-school proposal a clarification. The record shows a longstanding rule—and a meaningful expansion that deserves careful review.

Heath Vo, JD, CPA
Sep 66 min read


The IRS Says Taxpayers Can Get More Done Online. The Hard Cases Still Go Offline.
IRS online accounts now handle more tax tasks, but key limits remain. See what practitioners can resolve online—and when a tax case still has to go offline.

Heath Vo, JD, CPA
Aug 317 min read


The IRS Created an Office of Conservation Easements. Authority Will Decide Whether It Matters.
The IRS has centralized conservation-easement work, but it has not disclosed whether the new office can direct field resources, resolve BOD conflicts, or move a 1,100-case inventory.

Heath Vo, JD, CPA
Aug 249 min read


What the IRS Called “Abuse by Illegal Aliens” Is Really a New Refundable-Credit Status Test
The IRS framed its proposal as stopping refundable-credit abuse by illegal aliens. The actual rule is narrower, more technical, and could reach lawfully present noncitizens too.

Heath Vo, JD, CPA
Aug 227 min read
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