Category: Tax Law
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IRS Appeals: Hazards of Litigation, Cohan Rule & IRC §274(d) Explained | Brian Gilroy
When the IRS challenges deductions on your tax return, you don’t have to choose between accepting their position entirely or going to Tax Court. The IRS Independent Office of Appeals uses a principle called Hazards of Litigation to evaluate settlement possibilities based on what would likely happen if your case went to trial. Understanding how…
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IRS Appeals Technical Guidance Coordinators: Understanding Their Role | Brian Gilroy
Technical Guidance Coordinators Post – WordPress HTML When facing a complex tax dispute with the IRS, understanding how the Independent Office of Appeals operates can make the difference between a favorable settlement and an unfavorable outcome. One of the most important—yet least understood—aspects of Appeals is the Technical Guidance (TG) program and the role of…
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Understanding Representation Before the IRS Independent Office of Appeals | Brian Gilroy
IRS Appeals Representation Post – WordPress HTML When you disagree with the IRS about taxes owed, penalties assessed, or collection actions taken, you don’t have to accept their determination as final. The IRS Independent Office of Appeals provides a critical opportunity to resolve disputes fairly and impartially—without the expense and stress of going to court.…
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Innocent Spouse Relief: IRS Rules, Rev. Proc. 2013-34 & How Brian Gilroy Can Help
When you file a joint tax return with your spouse, you both become equally responsible for the entire tax debt—even if your spouse made errors or hid income without your knowledge. This joint liability can feel deeply unfair, especially in situations involving divorce, financial abuse, or deception. Fortunately, Innocent Spouse Relief under IRC § 6015…





