Blog Archives

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

Tagged with: , , ,
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

It has been QUITE a tax season! A Review of IRS Activity

According to the newly released 2012 IRS Data Book, the IRS collected almost $2.5 trillion in federal revenue and processed 237 million returns, of which almost 145 million were filed electronically. Out of the 146 million individual income tax returns filed,

Tagged with: , ,
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, Tax Court, Tax Fraud, Tax Guidance & Preparation

Loving v. IRS deals blow to IRS Regulation of Tax Return Preparers

In Loving v. IRS the IRS’ authority to regulate commercial tax return preparers has been successfully challenged. United States District Court for the District of Columbia Judge James E. Boasberg granted Loving’s motion for summary judgment describing the IRS Rules as "Ultra Vires."

Tagged with: ,
Posted in Enrolled Agent, IRS Enforcement, PTIN, Tax Abuse, Tax Court, Tax Fraud, Tax Guidance & Preparation, Tax Preparer, Tax Problems & Requests, Tax Whistle Blower, Taxpayer Advocate

What $$ IS Taxable: IRS Publication 525

Business Entity Selection and the Tax Consequences of Converting

I've been engaged in a running dialog with extraordinary nuances as to whether a loosely organized group of people are or are not fully recognizing taxable revenue from engagement in barter transactions with each other. The nuances inside this topic

Tagged with: , , ,
Posted in Barter, Gift Tax, Income, Tax Fraud, Tax Guidance & Preparation, Tax Problems & Requests, Tax Records, Taxable Income

IRS Stakeholder Liaison Meeting Summary

The following are the notes from the most recent IRS Stakeholder Liaison Meeting held in Denver Colorado as prepared by IRS Senior Stakeholder Liaison Deborah Rodgers Michael Shuler,  Local Taxpayer Advocate Nina Olson, the National Taxpayer Advocate’s (NTA) objectives report

Tagged with:
Posted in IRS Appeal, IRS Audit, IRS Centralized Insolvency, IRS Collections, IRS Criminal Enforcement, IRS Enforcement, IRS Examination, Tax Fraud, Tax Guidance & Preparation, Tax Preparer, Tax Problems & Requests, Taxpayer Advocate

Who Should I Hire To Do My Taxes?

Business Entity Selection and the Tax Consequences of Converting

We all know there are good and bad people everywhere, both inside the IRS and in the tax practitioner community alike.  Routinely readers of this blog report specific and egregious allegations of tax practitioner misconduct in violation of United States

Tagged with: ,
Posted in Estimated Taxes, PTIN, Tax Abuse, Tax Fraud, Tax Guidance & Preparation, Tax Preparer, Tax Relief, Taxpayer Advocate

Tax Practitioner Fraud and Incompetence US Treasury Circular 230

Business Entity Selection and the Tax Consequences of Converting

Lately I've been getting deluged with cases involving blatant US Treasury Circular 230 violators of regulations governing practice before the Internal Revenue Service. The perpetrators it seems come from all walks of life, some are unregulated tax return preparers while

Tagged with: , , ,
Posted in Tax Fraud

Reconstruction of Tax Records

Treasury Regulation 1.274-5 allows for a deduction without complete documentation if you can show that you have 'substantially complied' with adequate adequate record keeping requirements. This statute is code for ... be nice to your examiner. Basically the practice of disallowing

Tagged with: ,
Posted in IRS Appeal, IRS Audit, IRS Enforcement, IRS Examination, IRS Mediation, IRS Penalties, Tax Abuse, Tax Credit, Tax Deductible Expenses, Tax Fraud, Tax Guidance & Preparation, Tax Problems & Requests, United States Treasury

What taxes can be discharged in bankruptcy

Bankruptcy tax law is complicated and involves a firm grasp of time lines. Getting it right is complicated and requires reflective consideration. I learned this first hand back in 2004. If you get it wrong you loose the privilege of a

Tagged with: ,
Posted in Bankruptcy, Tax Fraud, Tax Guidance & Preparation, Tax Problems & Requests, Tax Relief

IRS Criminal Investigation Enforcement Trends

Hey everyone, check out what the Treasury Inspector General for Tax Administration is writing... "Criminal Investigation’s (CI) primary resource commitment is to develop and investigate legal source tax cases. The prosecution of these cases is key to supporting the Internal

Tagged with: ,
Posted in IRS Collections, IRS Enforcement, IRS Examination, Tax Fraud
Subscribe via Email

Schedule an Appointment
QuickBooks Advanced Certified ProAdvisors Online

QuickBooks Certified ProAdvisor - QuickBooks Online Advanced Certification