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 reporting issues, substantiation failures, and penalty challenges, with a focus on how courts are...
May 12
34 min
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 means for self-employment tax exposure and audit strategy. They then turn to a series of cautionary tales from the Ta...
Jan 26
30 min
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 consequential. Joel and Matt then turn to a series of jurisdictional case...
Dec 18, 2025
29 min
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 motive test to the material participation standards, Mary and Jos...
Dec 4, 2025
46 min
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 collection to refund claims and protective filings, Joel and Matt&n...
Nov 20, 2025
30 min
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 flights under TCJA, they break down the nuances that can make or break deductions...
Nov 6, 2025
29 min
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 avoiding common pitfalls, Mr. Crouch and Mr. Roberts share practic...
Oct 21, 2025
33 min
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 differences between advising government agencies and counseling ...
Oct 3, 2025
35 min
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 bonus and depreciation incentives, Mr. Crouch and Mr. Roberts h...
Sep 18, 2025
25 min
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 Section 530 relief and what to expect if the IRS challenges your cla...
Sep 4, 2025
27 min
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