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US v. Clarke SCOTUS Decision Favors Taxpayers

The SCOTUS clarified the 11th Circuit Court of Appeals in the United States v. Clarke Et. Al. that… “a taxpayer has a right to conduct an examination of IRS Officials regarding their reasons for issuing a summons when (s)he points to specific facts or circumstances plausibly

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Posted in IRS Audit, IRS Collections, IRS Enforcement, IRS Examination, IRS Penalties, IRS Penalty and Interest Abatement, Tax Abuse, Tax Court, Tax Deductible Expenses, Tax Guidance & Preparation, Tax Problems & Requests, Tax Relief

US v. Clarke SCOTUS Decision Favors Taxpayers

The SCOTUS clarified the 11th Circuit Court of Appeals in the United States v. Clarke Et. Al. that... "a taxpayer has a right to conduct an examination of IRS Officials regarding their reasons for issuing a summons when (s)he points to specific facts or circumstances plausibly

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Posted in Audit Reconsideration, Business Expense, IRS Enforcement, IRS Examination, Tax Abuse, Tax Court, Tax Deductible Expenses, Tax Guidance & Preparation, Tax Preparer, Tax Problems & Requests, Tax Relief

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

Form 5500 Pension Plan Penalty Filing Relief

For those of you like me presently wrestling with this issue the IRS recently came out with the following: Revenue Procedure 2014-32 establishes a one-year pilot program to provide relief to plan administrators who fail to timely file Form 5500

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Posted in Form 5500, IRS Enforcement, Penalty, Pension Plan, Tax Guidance & Preparation, Tax Problems & Requests

Reporting Investments In Certain Foreign Corporations for U.S. Tax Purposes

As we increasingly become more connected on this planet US Taxpayers are compelled more than ever before to hold investments in multiple countries. As a direct result timely filing IRS Form 5471 is becoming profoundly significant. I've been involved with enough international

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Posted in CFC, Corporation, FBAR, Foreign Income, International Tax, IRS Enforcement, IRS Examination, Tax Guidance & Preparation

IRS Bills, Penalties and Interest Charges

Many people have been reaching out to me to learn specifically about what they are up against for failing to hit the tax deadline of April 15th. To help those of you in this situation I've highlighted below what I

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Posted in IRS Collections, IRS Enforcement, IRS Penalties, IRS Penalty and Interest Abatement, Paying Taxes, Tax Guidance & Preparation, Tax Preparer, Tax Problems & Requests, Tax Refund, 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

Allowable Nontaxable IRA Rollovers Contributions Interpreted To Mean One Per Taxpayer Per Tax Year in US Tax Court Case – Bobrow v. Commissioner

In Bobrow v. Comm'r, T.C. Memo. 2014-21, the Tax Court relied on IRC 408(d)(3)(B) regarding the limits and frequency of nontaxable rollover contributions elected by the taxpayer noting that the one-year limitation addressed in this section of the US Tax Code applies

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Posted in Distributions, Investment Income, IRA, IRS Enforcement, IRS Examination, Retirement, Tax Court, Tax Guidance & Preparation, Tax Problems & Requests

What is a ‘Qualifying Relative’ for US Tax Purposes: IRC 152

Wading through the convolution required to identify specifically who qualifies as a relative for income tax reporting purposes oftentimes can be difficult, not because the actual tax code is difficult to understand in these regards or even subject to much

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Posted in Adoption, Child Tax, Children, Earned Income Tax Credit, IRS Enforcement, Tax Credit, Tax Deductible Expenses, Tax Filing Status, Tax Guidance & Preparation, Tax Problems & Requests
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