Blog Archives

IRS Practitioner Liaison Meeting Notes January 2018 – Denver

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

Denver IRS Practitioner Liaison Meeting Notes January 2018... I wasn't able to be present at the this most excellent semi-annual event but did send one of my top trusted lieutenants who came back with the following notes and permission to

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Posted in IRS Appeal, IRS Audit, IRS Collections, IRS Criminal Enforcement, IRS Enforcement, IRS Examination, IRS Levy, IRS Lien, IRS Rev. Proc

What to do WHEN you disagree with the IRS

The IRS Office of Appeals offers taxpayers an opportunity to resolve their tax disputes without going to court. Appeals is an independent function within the IRS that provides an impartial review of your tax dispute. Appeals also offers mediation services

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Posted in IRS Appeal, IRS Audit, IRS Collections, IRS Enforcement, IRS Examination, IRS Mediation

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

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

Marijuana Dispensary Income Tax Guidance Update: IRS Memo 201504011

Business Entity Selection and the Tax Consequences of Converting

As many of you know who follow my tax musings via this blog, I recently led a team of people that shepherded a Marijuana Dispensary through the IRS Examination and Appeals functions. The dispensary in question was owned and operated

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Posted in Amortization, Business Expense, Cash Transaction, Disallowed Expenses, IRS Appeal, IRS Audit, IRS Enforcement, IRS Examination, Marijuana

Odujinrin v. IRS Commissioner Reinforces the Significance of Engaging a Reputable Enrolled Agent

In Wole Odujinrin v. IRS Commissioner the petitioner, a hematology oncologist who represented himself, did not have adequate substantiation to support his petition and was not entitled to claim a net operating loss. He was also liable for an accuracy-related penalty

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Posted in Back Taxes Owed, Business Expense, Disallowed Expenses, Employee Business Expense, IRS Appeal, IRS Audit, IRS Collections, IRS Enforcement, IRS Penalties, IRS Penalty and Interest Abatement, Tax Abuse, Tax Court, Tax Guidance & Preparation, Tax Preparer

Denver IRS Practitioner Meeting July 2014 – A Summary Review with Excellent References for FBAR and FinCEN Matters

Meeting Summary as produced by IRS Senior Stakeholder Liaison Deborah Rodgers Nancy Carver, IRS Local Area Counsel Counsel continues to assist in training employees on partnership audits, and TEFRA. Counsel is also assisting in the investigations of promoters. Virtual currency

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Posted in IRS Appeal, IRS Audit, IRS Collections, IRS Criminal Enforcement, IRS Enforcement, IRS Examination, IRS Penalties, ITIN, Tax Abuse, Tax Guidance & Preparation, Tax Problems & Requests, Tax Refund

Use IRS Form 8082 to Report An Incorrectly Issued K1

This post address how to use IRS Form 8082 to report an incorrectly issued K1. The lesson learned is that you always start by requesting in writing that a corrected K1 be issued. I've been working a very complicated file

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Posted in 1231 Exchange, Asset Classification, Audit Reconsideration, Business Income, Capital Loss, Distributions, IRS Appeal, IRS Audit, IRS Collections, IRS Enforcement, K1, Partnership, Passive Activity, Sub-chapter S, Tax Guidance & Preparation, Tax Problems & Requests, Uncertain Tax Position

Decoding the IRS – Document 6209

Understanding what you are up against with the IRS can be frustrating on many levels. When it comes to the terminology they throw around, especially acronyms, what you will find is that even seasoned veterans quite often pull out specialty

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Posted in IRS Appeal, IRS Audit, IRS Centralized Insolvency, IRS Collections, IRS Enforcement, IRS Examination, IRS Levy, IRS Lien, IRS Mediation, IRS Penalties, IRS Penalty and Interest Abatement, IRS Transcript, Statutory Notice of Deficiency, Tax Guidance & Preparation, Tax Problems & Requests, Tax Relief

Top 8 Free US Tax Research Sites

The best free US tax research sites in my opinion are: 1. For actually referencing the US Tax Code - Cornell University Law School as they seem to do the best job with updates and maintenance and at the end

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Posted in IRS Appeal, IRS Audit, IRS Centralized Insolvency, IRS Collections, IRS Criminal Enforcement, IRS Enforcement, IRS Examination, IRS Levy, IRS Lien, IRS Mediation, IRS Penalties, IRS Penalty and Interest Abatement, IRS Transcript, ITIN, Tax Abuse, Tax Court, Tax Guidance & Preparation, Tax Problems & Requests, Tax Relief, Uncategorized, Uncertain Tax Position, United States Treasury

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
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