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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

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

US Treasury SS-8 Determination of Worker Status for Purposes of Federal Employment Tax

Business Entity Selection and the Tax Consequences of Converting

In my dealings with the US Treasury Department regarding worker classification disputes I have learned that although in reality there may be shades of gray distinguishing between what constitutes an employee and what constitutes an independent contractor the US Treasury

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Posted in Appeals & Audit Resolution, Audit Reconsideration, Business Expense, Employee Business Expense, Employment Tax, FICA, Payroll Tax Problems, Self Employ, Small Business, Sub-chapter S, Tax Guidance & Preparation, United States Treasury, Worker Classification

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

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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

Small Business Lending Fund – available now for a short time – if you need a loan and you are a subchapter S – get on this.

Subchapter S corporations and mutual institutions participating in the Small Business Lending Fund will benefit from the incentives the Fund provides for increased lending. The more an institution increases its small business lending, the lower the rate it will receive. The application deadline for

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Posted in Sub-chapter S, United States Treasury
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