Blog Archives

U.S. Tax Court Settlements in IRS Appeals

U.S. Tax Court Settlements in IRS Appeals

Situations by which Docketed U.S. Tax Court Cases Settle in IRS Appeals

Tagged with: , , , ,
Posted in Appeals & Audit Resolution, IRS Appeal, IRS Enforcement, Tax Court, Tax Relief, United States Treasury

Schumann v. IRS: Reg. 1.469-2(f)(6) – The Nuanced Relationship Between Passive Losses & Self Rental Gains

The Perturbing New Treatment of Patents Under the Tax Cut & Jobs Act (TCJA)

Schumann v. IRS: Reg. 1.469-2(f)(6) - The Nuanced Relationship Between Passive Losses & Self Rental Gains. Back to my friends that I previously wrote about who misunderstood passive activity and material participation. They are a married couple filing jointly and own

Tagged with: , ,
Posted in 1031 Exchange, Appeals & Audit Resolution, Business Expense, Business Income, Deductible Expense, Disallowed Expenses, IRS Examination, Material Participation, Passive Activity, Rental Real Estate, Self Rental, Sub-chapter S, Tax Court, Tax Guidance & Preparation

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

Tagged with: ,
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 Audit Musings

If you chose to represent yourself in an IRS Examination realize the IRS Revenue Agent (RA) or Tax Compliance Officer (TCO) assigned your file is trained very thoroughly to advocate on behalf of the US Government. One method used quite often

Tagged with: , , , , , , , , , ,
Posted in Appeals & Audit Resolution, Audit Reconsideration, Audit Technique Guide, IRS Appeal, IRS Audit, IRS Collections, IRS Criminal Enforcement, IRS Enforcement, IRS Examination, IRS Levy, IRS Lien, IRS Mediation, IRS Penalties, IRS Penalty and Interest Abatement, Uncategorized

Trafficking under IRC § 280E

Business Entity Selection and the Tax Consequences of Converting

The Internal Revenue Code is a complex beast.  In the lunacy of it all I've been asked to define 'trafficking' as it relates to 26 USC § 280E - Expenditures in connection with the illegal sale of drugs which states as follows: "No

Tagged with: , , , , , , ,
Posted in Appeals & Audit Resolution, Asset Classification, Business Expense, Cash Transaction, COGS, IRS Mediation, Marijuana, Net Operating Loss, NOL, Tax Abuse, Tax Court, Tax Guidance & Preparation, Tax Problems & Requests

IRS Restrictions on Contacting Taxpayers

I've worked with many good people inside the IRS on a wide variety of cases. So please do not get me wrong I'm not bashing ALL IRS employees. However like any big bloated bureaucracy I've also worked with some real

Tagged with: ,
Posted in Appeals & Audit Resolution, Audit Reconsideration, Audit Technique Guide, IRS Appeal, IRS Audit, IRS Collections, IRS Criminal Enforcement, IRS Enforcement, IRS Examination, IRS Mediation, Tax Abuse, Tax Guidance & Preparation, Tax Relief, Taxpayer Advocate, TIGTA

Ex Parte Communication and IRS Appeals – Rev. Proc. 2012-18

Business Entity Selection and the Tax Consequences of Converting

Ex parte communication is oral or written communication that takes place between any IRS Appeals employees such as Appeals Officers, Settlement Officers, Appeals Team Case Leaders, Appeals Tax Computation Specialists and employees of other IRS functions without the taxpayer's representative being given an

Tagged with: , , , , ,
Posted in Appeals & Audit Resolution, IRS Appeal

US Treasury SS-8 Determination of Worker Status for Purposes of Federal Employment Tax

Business Entity Selection and the Tax Consequences of Converting

In my dealings with the US Treasury Department regarding worker classification disputes I have learned that although in reality there may be shades of gray distinguishing between what constitutes an employee and what constitutes an independent contractor the US Treasury

Tagged with: , , ,
Posted in Appeals & Audit Resolution, Audit Reconsideration, Business Expense, Employee Business Expense, Employment Tax, FICA, Payroll Tax Problems, Self Employ, Small Business, Sub-chapter S, Tax Guidance & Preparation, United States Treasury, Worker Classification

Updated Rules Issued for IRS Communications with Appeals Office – Rev. Proc. 2012-18

The IRS Office of Appeals resolves more than 100,000 tax cases each year. Employees staffed in this function are trained to resolve disputes taking into consideration the hazards of litigation as well as the benefits of efficient tax administration. They are not

Tagged with: , , ,
Posted in Appeals & Audit Resolution, IRS Appeal

Dwelling Unit vs. Primary Residence

Many taxpayers have both a dwelling unit and a principal place of residence.  Understanding the difference between the two is important for a wide variety of reasons.  The file that landed on my desk today involves such a matter.  The

Tagged with: ,
Posted in Appeals & Audit Resolution, IRS Appeal, IRS Audit, IRS Enforcement, IRS Examination, Rental Real Estate, Tax Guidance & Preparation, Tax Problems & Requests, Uncertain Tax Position
Subscribe via Email

Schedule an Appointment
QuickBooks Advanced Certified ProAdvisors Online

QuickBooks Certified ProAdvisor - QuickBooks Online Advanced Certification