The 2024 IRS Data Book released in April 2025 contains audit statistics for years 2014 through 2022, as of the fiscal year ended September 30, 2024 (FY 2024). For tax years 2020 and earlier, the statute of limitations for audits had generally expired as of September 30, 2024. However, for 2021 and later returns, the statute of limitations has yet to expire, so additional returns of those years may be audited.
For 2014 through 2022, audit rates dropped significantly. For example, individual tax returns had an audit rate of 0.6% for 2014 returns versus 0.2% for 2022 returns. For individuals with income between $1 million and $5 million, the audit rate dropped from 2.7% for 2014 returns to 1.1% for 2022 returns.
Two recent personal events had me thinking lately about the tension between innovation and individual rights, and the risk decisions we make to find a happy medium. The first event was the purchase of a car, necessitated by someone rear-ending my 2004 Honda. Being from Cleveland, it is logical to me to drive a vehicle into the ground, and I was perfectly happy with my ride. (So were the mice in our garage, but that is another story. I will say, however, that Irish Spring soap does work.) Although my kids derided me about the low tech, I didn’t realize what I was missing until I started driving the new car – a previously owned 2019 model with a more fulsome tech package. I had a fleeting thought about vetting the apps before connecting my personal devices, but with the promise of life-changing results, I forged ahead and am happily enjoying the benefits. An easy risk decision. The second event was our power going out as a result of a recent storm. Our power did not just go out for a few hours like our neighbors. Instead, when the electric company fixed the problem, the power surge killed our aging breakers, and we were without power – for over . . . twenty . . . four . . . hours. (Ellipses for dramatic effect. It actually wasn’t so bad.) I learned, however, that a high-end smart breaker panel may have given us some warning, and at the very least saved me from a bad hair day. But smart devices mean sharing information. And again, there’s that tension.
https://ncbarblogprod.wpengine.com/wp-content/uploads/2018/06/Blog-Header-1-1030x530.png00Privacy and Data Securityhttps://ncbarblogprod.wpengine.com/wp-content/uploads/2018/06/Blog-Header-1-1030x530.pngPrivacy and Data Security2025-07-29 14:02:582025-08-18 09:48:45The Chair's Column, July 2025
Bradley Arant Boult Cummings LLP Welcomes New Partner
Elizabeth F. Greene has joined the firm. Before joining Bradley Arant Boult Cummings LLP, she managed a regional white-collar and investigations firm in Charlotte. She brings more than 20 years of experience as a trial attorney in high-stakes litigation. Greene practiced as an assistant United States attorney in the Western District of North Carolina and an assistant district attorney in Mecklenburg County. She served as in-house counsel for a large national mortgage lender. She previously was a prosecutor with the United States Department of Justice. Greene assists clients in complex criminal matters in both state and federal court, False Claims Act violations, professional licensing, and other regulatory matters. She regularly conducts internal investigations for businesses. She holds a J.D. from Campbell Law School and a B.A. in English literature from the University of Virginia.
Law Firm Carolinas Names New Partner
Jonathon Woodruff is a partner with the firm. He joined Law Firm Carolinas in 2021, and his practice is focused on representing community associations, including HOAs and condominium associations. Woodruff has experience in civil law and criminal law. He supervises the firm’s association assessment collections practice. He has been involved in his community through service with Blanchard Community Law Clinic, the Restorative Justice Clinic and Shiloh Missionary Baptist Church. Woodruff, who is a native of Winston-Salem, earned his J.D. from Campbell Law School, where he served as the president of the Black Law Student Association and as the 3L representative for the Student Bar Association. He holds a bachelor’s degree in psychology from North Carolina Central University.
As paralegals, we do not get to choose whether we are OK with change or not. We have to adapt, roll with the punches, and somehow keep things moving, regardless of what is going on around us.
2020 changed many things in our legal world, but we learned from that time. For example, we learned that it is entirely possible to work remotely without being chained to our desks and offices. We realized technology could be used to make things more efficient. Just a few years prior to 2020, Zoom meetings were not a thing, but now, not only are they possible, but they are sometimes preferred.
https://ncbarblogprod.wpengine.com/wp-content/uploads/2018/06/Blog-Header-1-1030x530.png00Paralegalshttps://ncbarblogprod.wpengine.com/wp-content/uploads/2018/06/Blog-Header-1-1030x530.pngParalegals2025-07-28 11:33:102025-07-28 11:33:10How Changes in Law Affect Paralegal Work
Welcome to the Construction Law Section for the new NCBA year!
I am honored and humbled to serve as Chair of the NCBA Construction Law Section for this year. I am thankful for the work of many, many others before me, not the least of whom is Caroline Trautman, the Immediate Past Chair. Through Caroline’s leadership during the past year, our section continued its member services through CLE, disaster relief and pro bono efforts, updates to our Section’s Construction Law Deskbook, blog posts, and many other section activities and bar service opportunities.
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Dear Members of the NCBA Corporate Counsel Section,
I am thrilled to welcome you to the 2025-2026 bar year! My name is Nickeyea Wilkinson-Pickett, and I am delighted to introduce myself as our section chair for this exciting year. It is truly an honor to serve in this role, and I am enthusiastic about the opportunities that lie ahead for us to work together.
As we embark on this new bar year, I am eager to collaborate with you to propel our section even further. Our collective efforts will undoubtedly lead to a productive and successful year, filled with engaging events, valuable networking opportunities, and enriching professional development.
Please be on the lookout for additional information about our future events and meetings. We have an exciting year planned, and I am confident that you will find it both informative and enjoyable. Your participation and input will be crucial in shaping the direction of our section, and I encourage you to get involved and share your ideas!
Thank you for your commitment to the NCBA Corporate Counsel Section. I look forward to an amazing year ahead and to the opportunity to work alongside such a talented and dedicated group of professionals.
https://ncbarblogprod.wpengine.com/wp-content/uploads/2018/06/Blog-Header-1-1030x530.png00CorporateCounselhttps://ncbarblogprod.wpengine.com/wp-content/uploads/2018/06/Blog-Header-1-1030x530.pngCorporateCounsel2025-07-24 11:21:262025-07-24 11:30:09A Welcome Message From the Chair
Woodson claims are wrongful death tort actions arising from workplace injuries, typically brought outside the scope of workers’ compensation. Originating from the seminal case Woodson v. Rowland, 329 N.C. 330, 407 S.E.2d 222 (1991), these claims frequently arise in the context of construction accidents and involve egregious employer misconduct. Typically, parties injured at work can only bring claims under workers’ compensation, and not tort actions, such as for wrongful death. North Carolina recognizes a narrow exception that permits tort claims for workplace injuries caused by an employer’s intentional misconduct or “conduct that, while not categorized as an intentional tort, was nonetheless substantially certain to cause serious injury or death to the employee.” Valenzuela v. Pallet Express, Inc., 207 N.C. App. 364, 367, 700 S.E.2d 76, 79 (2010) (citing Whitaker v. Town of Scotland Neck, 357 N.C. 552, 556, 597 S.E.2d 665, 667 (2003)).
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Limited Liability Companies (or LLCs) were invented in Wyoming in 1977. They have since spread to all states and become one of the most popular entities to use for businesses. From a tax perspective, LLCs are hybrid entities that can elect to be taxed in a number of different ways. Regulations that became effective in 1997 (commonly referred to as the “check-the-box regulations”) provide tax classification. Treas. Reg. § 301.7701-1, et. seq.
Treas. Reg. § 301.7701-3(b)(1) describes the default treatment of LLCs where no check-the-box election is made. The default treatment of an LLC with a single owner is as an entity disregarded as separate from its owner for income tax purposes. Treas. Reg. § 301.7701-3(b)(1)(ii). As a disregarded entity, the LLC has no federal income tax filing requirements. Its activities (including income and loss) are instead reported on the tax return of its sole owner. Where an LLC has more than one owner, the default treatment is as a partnership. It is required to file an annual Form 1065 to report the pass-through income and loss allocated to its partners.
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Brett Cosgrove is a litigation paralegal with almost 30 years of experience in personal injury, medical malpractice and complex civil litigation. She has two children and six grandchildren who live in different parts of the country. Outside of work, Brett enjoys hiking, reading, cooking and baking, traveling in their RV, and spending time with her husband and their Rottweiler, Veruca.
A Purposeful Path to the Law
Brett Cosgrove didn’t begin her career in law, but once she discovered it, she never looked back. While living in Arizona, Brett spent several years working in operations for a cable-locating company, where she traveled extensively across the country setting up offices and working in the field. Though the job was steady, she knew it wasn’t her long-term path.
A conversation with a friend who was an accountant sparked her interest in the legal profession. Inspired and curious, Brett enrolled in night classes to earn her associate’s degree in paralegal studies and took a part-time position with a sole practitioner assisting his paralegal, all while continuing to work her full-time position with the cable-locating company.
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Jonathon Woodruff is a partner with the firm. He joined Law Firm Carolinas in 2021, and his practice is focused on representing community associations, including HOAs and condominium associations. Woodruff has experience in civil law and criminal law. He supervises the firm’s association assessment collections practice. He has been involved in his community through service with Blanchard Community Law Clinic, the Restorative Justice Clinic and Shiloh Missionary Baptist Church. Woodruff, who is a native of Winston-Salem, earned his J.D. from Campbell Law School, where he served as the president of the Black Law Student Association and as the 3L representative for the Student Bar Association. He holds a bachelor’s degree in psychology from North Carolina Central University.
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