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aallenlenth Archive

Revisiting Supervisory Approval For Accuracy Penalties

TweetShareSharePin0 Shares Today’s post comes from University of Minnesota Law student, Patrick Riley Murray. Mr. Murray is not actually one of my students in my Federal Tax Procedure or the Federal Tax Clinic courses. However, Mr. Murray was referred to me by a student and previous Procedurally Taxing contributor Casey Epstein (see post here), as

Sorting out tax exempts’ UBTI painlessly

TweetShareSharePin0 Shares Two digits are mostly better than six In comments to the IRS on the proposed regulations, the AICPA called for much broader two-digit codes to eliminate the complexity posed by using six, and opposed mandating the codes’ use. The new silo requirement originally “created a lot of confusion and left people guessing,” Heller

Death and Taxes

TweetShare1SharePin1 Shares On the substantive side of tax issues Congress is focusing on death and taxes as it studies and debates whether to eliminate the stepped up basis currently given to property upon the death of the owner.  This debate is not new.  When I was in law school in the mid-1970s taking a class

Innocent Spouse Relief: Understanding the Requirements

TweetShare1SharePin1 SharesThis short article clarifies exactly how innocent spouse relief works as well as exactly how one can get approved for it. A joint tax obligation filing return makes both parties in charge of the tax obligation bill. It eliminates the requirement to foot additional tax debt with an innocent spouse relief if your companion

Innocent Spouse Relief – Defined

TweetShare1SharePin12 SharesInnocent spouse relief can be used when one spouse of a joint return is assessed additional tax based on the erroneous filing by the other spouse. This method can be extremely complex and usually involves the assistance of a tax attorney, but can be a viable option depending on the circumstances. Notice: JavaScript is

IRS Form 8379: Injured Spouse Allocation

TweetShare1SharePin1 SharesThe Internal Revenue Service (IRS) has the power to seize income tax refunds when a taxpayer owes certain debts, such as unpaid taxes or overdue child support. Sometimes, a married couple’s joint tax refund will be seized because of a debt for which only one spouse is responsible. When that happens, the other spouse
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