Blog Archives

Protecting Americans from Tax Hikes (PATH) Act of 2015 – A Summary

Protecting Americans from Tax Hikes Act of 2015 (PATH) summarized by my friend Shirley Callahan EA. Some highlights include: Everyone will appreciate the permanency of the enhanced Educator Expenses, the Sales Tax deduction, and the R&D Credit. Section 179 is made

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Posted in DIY, Enrolled Agent, IRS Collections, IRS Criminal Enforcement, IRS Enforcement, IRS Examination, IRS Mediation, IRS Penalties, IRS Penalty and Interest Abatement, ITIN, Licensed Tax Professional, PATH Act 2015, Paying Taxes, Penalty, Tax Abuse, Tax Court, Tax Credit, Tax Fraud, Tax Guidance & Preparation, Tax planning, Tax Preparer, Tax Problems & Requests

Coca Cola’s Recent IRS Statutory Notice of Deficiency – a Tipping Point in International Transfer Pricing Enforcement

In Coca Cola's SEC 8-K filing last week we learned that the IRS issued a $3.3 Billion statutory notice of deficiency against the company as the result of a 5 year long transfer pricing audit covering tax years 2007-09. This is very BIG when

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Posted in Foreign Income, Foreign Investment, International Tax, IRS Examination, Tax Abuse, Tax Court, Transfer pricing

Why to Revoke An S Election and How to Do It – Internal Revenue Code Section 1362(d); Reg § 1.1362­6(a)

Many entrepreneurs get caught up in selecting the "most appropriate business structure" - particularly people planning to conquer the moon right out of the gate. If this is you beware as business structure is a determination that is best driven out

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Posted in Employment Tax, Entity Classification, Paying Taxes, Payroll Tax Problems, Penalty, Small Business, Social Security, Social Security Tax, Sole Proprietor, Start up costs, Sub-chapter S, Tax Abuse, Tax Guidance & Preparation, Tax Problems & Requests

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

A Brief Introspection of Repair vs. Improvement: IRS Revenue Procedures 2014-16 and 2014-17

That's right Y'all this is another one of those quite game changers for owners of tangible property concerned about keeping the IRS at bay by actually adhering to the specific US Tax Code and subsequent IRS Revenue Procedures. My apologies for

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Posted in 1031 Exchange, Business Expense, Depreciation, Rental Real Estate, Sole Proprietor, Tax Abuse, Tax Guidance & Preparation, Tax Problems & Requests

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

Defending Against Alter Ego Allegations

What is an "alter ego" allegation? Aside of course being one of several nuanced yet distinct stages of intoxication, when it comes to the IRS it seems from my perspective that there are several elements of the alter ego doctrine

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Posted in Alter Ego, Sub-chapter S, Tax Abuse, Tax Deductible Expenses, Tax Fraud, Tax Guidance & Preparation, Tax Preparer, Tax Problems & Requests, Tax Relief, Trusts, Uncertain Tax Position, United States Treasury

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
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