A quarterly magazine from the National Association of Enrolled Agents
Winter 2025 vol.43 no.4
When the Burden Shifts: Understanding Internal Revenue Code §7491(a)
Feature Article

When the Burden Shifts: Understanding Internal Revenue Code §7491(a)

The burden of proof in tax disputes generally is with the taxpayer, as established by Welch v. Helvering, 290 U.S. 111 (1933),i unless the taxpayer satisfies the conditions for burden shifting ... DeShawn King, EA

Fall 2025, Feature Article, IRS Restructuring and Reform Act of 1998, Cohan rule, §274(d), IRC §7491(a), Welch v. Helvering, §6001, §7491(c), burden of proof, Higbee v. Commissioner, Estate of Bongard, §2036
The Practitioner’s Duty to Help Business Owners with Recordkeeping
Feature Article

The Practitioner’s Duty to Help Business Owners with Recordkeeping

As the nation’s tax experts, enrolled agents (EAs) crucially influence taxpayers’ financial well-being and compliance with tax laws and regulations. A critical aspect of this role includes confirmin... Jeremy Wells, EA, CPA

Summer 2023, Feature Article, business, ethics, §7203, recordkeeping, Cohan rule, §274(d), §6662(a), bookkeeping, do-it-yourself, DIY, §7491