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

Postings on www.IRS.gov are NOT Necessarily Legal Authority

Postings on www.IRS.gov are NOT Necessarily Legal Authority

Postings on www.IRS.gov are NOT Necessarily Legal Authority

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Posted in IRS Audit, IRS Enforcement, IRS Examination

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

Why You Should File Past Due Tax Returns NOW

Regardless of whether or not you are able to pay your tax liability in full, you should file all tax returns that are due. To do so, file your past due return the same way that you would file a

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Posted in IRS Collections, IRS Enforcement, IRS Mediation, IRS Penalties, Non-filed Tax Returns, Penalty, Tax Guidance & Preparation, Tax planning, Tax Problems & Requests, Taxpayer Advocate

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

Disability portion of SSA benefits (SSDI) will be removed from the FPLP 15% Levy for Past Due Tax Assessments

This is really confusing folks! On the one hand those of us who follow closely generally tend to believe that there is a LOT of rampant fraud in SSI Disability benefits practices these days but this news is going to

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Posted in Disability, IRS Enforcement, IRS Levy, Social Security, SSI

Releasing a Federal Tax Lien from the IRS – A Step by Step Guide

Fortunately I graduated from providing this service for hire preferring to refer all tax collection work to a handful of trusted friends and advisers consciously choosing (bless their hearts) to focus solely on Section 6325(a) of the Internal Revenue Code that

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Posted in IRS Collections, IRS Enforcement, IRS Levy, IRS Lien

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

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
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