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
Representing the Profession: Serving Tax Professionals on the Electronic Tax Administration Advisory Committee
Internal Revenue Service

Representing the Profession: Serving Tax Professionals on the Electronic Tax Administration Advisory Committee

After serving on the National Association of Enrolled Agents (NAEA) Board of Directors for seven years, I was looking for a new challenge. Not that living and working in the Florida Keys is not fulfilling, but being involved at the national level, tackling issues of im... Jerry Gaddis, EA, NTPI Fellow®

Fall 2025, Internal Revenue Service, IRS Restructuring and Reform Act of 1998, Electronic Tax Administration Advisory Committee, ETAAC, Internal Revenue Service Advisory Council, IRSAC, Federal Advisory Committee Act, FACA
The $80 Billion Question
Feature Article

The $80 Billion Question

On November 10, 2022, President Joe Biden nominated Danny Werfel to succeed Chuck Rettig as Commissioner of Internal Revenue.i Danny—or more formally, Daniel I.—Werfel testified on February 15, 2023, before the Senate Finance Committee, led by C... Robert Kerr, EA

Mar/Apr 2023, Feature Article, Internal Revenue Service, IRS, commissioner, Inflation Reduction Act, Werfel confirmation hearing, IRS Restructuring and Reform Act of 1998, 26 USC §7803(1)(B))