tax Advice Archive
TweetShareSharePin0 Shares We have not covered IRC 66(c) relief from community property taxation in detail on PT before. Keith wrote about the 2018 case of U.S. v. Kraus, where the grant of personal relief under IRC 66 failed to lift the federal tax lien or prevent foreclosure of the lien. (Similar hurdles exist with IRC
TweetShareSharePin0 Shares We welcome back guest blogger Barbara Heggie. Barb is the supervising attorney for the Low-Income Taxpayer Project of 603 Legal Aid in Concord, New Hampshire. Her clinic serves taxpayers through the Granite State and is the only LITC in the state. Today, she describes a recent experience in trying to assist a client.
TweetShareSharePin0 Shares The question of when a supervisor must give approval for imposition of a penalty has created much litigation in the Tax Court as taxpayers try to remove a penalty proposal by using the failure of the IRS to comply with the IRC 6751(b) approval process. In Laidlaw’s Harley Davidson Sales v. Commissioner, No.
TweetShareSharePin0 Shares When Congress passed the Foreign Account Tax Compliance Act (FATCA) (as part of the Hiring Incentives to Restore Employment Act, P.L. 111-147) in 2010, the Joint Committee on Taxation estimated it would bring in $8.7 billion in revenues in the next 10 years. To that end, the IRS drafted an ambitious, agencywide FATCA
TweetShareSharePin0 Shares News PARTNERS & PARTNERSHIPS By Paul Bonner The IRS has added eight new questions and answers to its website’s frequently asked questions (FAQs) on Schedules K-2 and K-3, clarifying that affected partnerships and S corporations need complete only the forms’ relevant portions and addressing an array of special circumstances. The new material
TweetShareSharePin0 Shares A couple of months ago in 11th Circuit Remands Willful FBAR Penalty Case Back to IRS Due to APA Violation I blogged about Schwarzbaum v United States, where the Eleventh Circuit held that Schwarzbaum willfully violated his FBAR reporting obligations for three years but that the IRS miscalculated the FBAR penalties. As I discussed,
TweetShareSharePin0 Shares Taxpayers who may need to take additional actions related to qualified opportunity funds (QOFs) should begin receiving letters in the mail in April. the IRS announced Tuesday. The IRS said it will begin sending letters this month to taxpayers, including corporations or partnerships organized as a QOF, whose Form 8996, Qualified Opportunity Fund,
TweetShareSharePin0 Shares The 2021 tax filing season featured IRS administrative challenges that were unprecedented in scope but long-standing in their causes, the U.S. Government Accountability Office (GAO) said in a report released Monday. And while the issues uncovered in the GAO’s study mostly stemmed from the COVID-19 pandemic’s continuing effects, they are likely to persist
TweetShareSharePin0 Shares 0 Flares Filament.io Made with Flare More Info“> 0 Flares × It is a busy couple of weeks for blogging crew. For those wanting a fix of tax administrative news pending our next substantive post, we recommend taking a look at the GAO report 2021
TweetShareSharePin0 Shares In The IRS Primarily Uses Lien Foreclosures When Pursuing Principal Residences, Which Do Not Provide the Same Legal Protections as the Seizure Process TIGTA released a report detailing how IRS uses judicial lien foreclosure suits rather than administrative collection tools when it targets a taxpayer’s principal residence to satisfy an assessed liability. The