Blog Archives

Understanding Your Odds with IRS Audit Technique Guides

Many taxpayers fear that aggressive deductions wave flags in front of IRS auditors and quite often I am asked what the chances are of being audited as if my opinion is some sort of a benchmark. The fact of the matter

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Posted in Abusive Tax Shelter, Appeals & Audit Resolution, Audit Reconsideration, Audit Technique Guide, Business Expense, Business Income, IRS Appeal, IRS Audit, IRS Collections, IRS Enforcement, IRS Examination, IRS Mediation, IRS Penalty and Interest Abatement, IRS Transcript

Tax Treatment of Liabilities Assumed by a Corporation IRC 357 – What is Boot?

According to IRC 357(a) if property transferred to a corporation in an IRC 351 nonrecognition transaction is subject to a liability, the assumption of that liability by the corporation generally is not treated as taxable "boot" for purposes of determining the amount

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Posted in Abusive Tax Shelter, Basis, Boot, Capital Gain, Capital Loss, Cash Transaction, Deductible Expense, Distributions, Tax Guidance & Preparation

Lessons From Mitt Romney’s Tax Return

Business Entity Selection and the Tax Consequences of Converting

Check out Mitt Romney's 2010 tax return and learn how he does it. The most important lesson I learned in perusing his return (besides the significance of sheltering your $$ outside of the USA) is the immediate impact of targeted charitable contributions.

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Posted in Abusive Tax Shelter, Accounting Method, Alternative Minimum Tax (AMT), Asset Classification, Audit Technique Guide, Basis, Business Expense, Business Income, Charitable Contribution, Cost Basis, Mitt Romney Taxes

IRS Audit Guidelines Assessing Asset Dissipation

If you are delinquent on taxes you may be considering some IRS payment arrangement whereby your total tax liability will be considered satisfied in exchange for a payment plan that is less then the full amount owed. Two different plans that

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Posted in Abusive Tax Shelter

Abusive Tax Shelters

Abusive tax shelters of every nature are what I call scum bag lawyer schemes.  It is difficult to specifically define abusive tax shelters because new ones are constantly emerging.  Essentially they are arrangements usually designed by 'promoters' to circumvent tax

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Posted in Abusive Tax Shelter

IRA’s Cannot Hold Sub-Chapter ‘S’ Stock: Trusts Can Though

To be taxed as an S corporation, a C corporation must elect S status by filing IRS Form 2553. Electing S status is fairly simple for a new or existing corporation, but meeting the requirements for S status can be more complex when the

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Posted in Abusive Tax Shelter, Entity Classification, Self Employ, Small Business, Sole Proprietor, Sub-chapter S, Tax Abuse, Tax Court, Tax Fraud, Tax Guidance & Preparation

Tax Strategy Patents + Patent Applications

I am opposed to all tax strategy patents.  They are bad public policy and harmful to taxpayers and their advisers.  No one should have a monopoly on part of the tax code and no taxpayer should be subject to paying

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Posted in Abusive Tax Shelter, Colorado Department of Revenue, Estimated Taxes, IRS Appeal, IRS Audit, IRS Collections, IRS Enforcement, IRS Examination, IRS Levy, IRS Lien, IRS Mediation, IRS Penalties, IRS Penalty and Interest Abatement, Private Letter Ruling, Tax Abuse, Tax Problems & Requests, Tax Relief, Tax Whistle Blower

What is an Abusive Tax Shelter?

An abusive tax shelter generally offers inflated tax savings which are disproportionately greater than your actual investment placed at risk. Usually you invest money to generate income or capital appreciation but an abusive tax shelter generates little or no income

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Posted in Abusive Tax Shelter, IRS Appeal, IRS Audit, IRS Collections, IRS Enforcement, IRS Examination, IRS Mediation, IRS Penalty and Interest Abatement, Tax Abuse, Tax Fraud, Tax Guidance & Preparation, Tax Problems & Requests

IRS Issues Prohibited Tax Shelter Final Regulations

IRS Issues Prohibited Tax Shelter Final Regulations http://www.irs.gov/pub/irs-tege/4965fregs.pdf

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Posted in Abusive Tax Shelter, IRS Enforcement, Paying Taxes, Tax Abuse, Tax Fraud, Tax Guidance & Preparation

Abusive Home-Based Business Tax Schemes – Misuse of the Law

The IRS has uncovered a number of schemes that claim to allow deductions for personal living expenses. Taxpayers should consider these points before investing in a possible abusive scheme: Any investment scheme or promotion that claims to allow a federal

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Posted in Abusive Tax Shelter, Back Taxes Owed, Home Office, Self Employ, Small Business
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