tax Advice Archive
Approving Presents from the Internal Revenue Service: Moral Factors To Consider (Sequel)
April 21, 2021
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TweetShareSharePin0 SharesFormerly, we reviewed both groups of Internal Revenue Service “presents” that taxpayers can decline: clerical presents and also totally computational presents. We left, nonetheless, with the cliffhanger that computational presents might end up being “theoretical” presents, which lawyers frequently can approve. Today, we’ll look better at what a theoretical present is and also whether
Internal Revenue Service expands e-signature permission for 6 months
April 21, 2021
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TweetShareSharePin0 Shares Information Treatment & & Management By Sally P. Schreiber, J.D. In a memorandum dated April 15, 2021, the Internal Revenue Service introduced it was prolonging the permission to digitally authorize a a great deal of Internal Revenue Service kinds till Dec. 31, 2021, and also including a variety of brand-new kinds. The initial
Approving Presents from the Internal Revenue Service: Honest Factors To Consider (Component One)
April 20, 2021
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TweetShareSharePin0 SharesFor questions on this and other tax issues please visit ETS @ Executive Tax Solution Formerly, I blogged about the unusual instance of Owner v. C.I.R (here). As a refresher course, the Householders attempted to take around half-a-million bucks in rubbish reductions for their steed breeding/leasing “company,” as well as the Tax obligation Court
IRS Agent Seizes Valuable Coins and Taxpayer Sues for Conversion
April 19, 2021
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TweetShareSharePin0 Shares Willis v Boyd, an opinion from the 8th Circuit Court of Appeals, is not a typical tax collection case. The opinion involves an IRS agent who seized 364,000 one dollar coins that were issued to commemorate US presidents. After seizing the coins, which were in special boxes in original packaging consisting of 1,000 coins,
Impact of Initial Exclusion from EIP of U.S. Citizens Filing Jointly with Non-Citizen Spouses
April 19, 2021
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TweetShareSharePin0 Shares We welcome two students from the Georgia State University College of Law Philip C. Cook Low-Income Taxpayer Clinic as guest bloggers, Lauren Zenk and Lauren Heron, for a discussion of the latest developments in stimulus payment legislation as it relates to U.S. citizens who file jointly with non-citizens spouses. The Georgia State Clinic
Does the Golsen Rule Apply to Tax Court Rules?
April 19, 2021
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For many years the Tax Court did not concern itself with circuit court precedent in deciding cases and decided cases as it thought best. The leading case for the Tax Court’s thinking on this
Sixth Circuit Weighs in On Sovereign Immunity and Exceptions to Notice in Third-Party Summons Case
April 19, 2021
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TweetShareSharePin0 Shares When IRS issues a summons to third parties it generally has to notify the taxpayer whose records are identified. That right to notice is key, as it triggers a correlative right to bring an action in district court to challenge the summons and allows for limited judicial review of IRS’s vast information gathering
5th International Conference on Taxpayer Rights – Registration is Now Open
April 19, 2021
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TweetShareSharePin0 Shares Sometimes, in the midst of all that is going on in one’s own professional life, it helps to take a step back and think about first principles of tax administration. It is also fascinating to learn about tax administration in countries not your own – so that you look at your own tax
Sixth Circuit Holds that State Court Judge’s Failure To Pay Taxes Was Willful for Purposes of Bankruptcy Discharge Rule
April 19, 2021
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Your bloggers have had lots on their plate this week, so we apologize for the lighter than usual coverage. Luckily, others, like Jack Townsend, who in addition to working with me to cover criminal
Appointing a Receiver to Protect Value and Innocent Third Parties
April 19, 2021
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TweetShareSharePin0 Shares The Supreme Court has said that Congress could not have written a broader lien than the federal tax lien. In addition to the lien, Congress gave the IRS broad powers to take property through levy in IRC 6331. We can think of these administrative powers as the superpowers bestowed upon the IRS in