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How Biden Business Tax Proposals Would Impact Taxpayers Across States

TweetShareSharePin0 Shares The Biden administration has proposed several tax increases on businesses, whether structured as C corporations subject to the corporate income tax or passthrough entities such as S corporations, partnerships, or sole proprietorships that are subject to the individual income tax. It is important to remember that those business taxes ultimately fall on people,

IRS Wins Lien Priority Fight with Bank

TweetShareSharePin0 Shares In Citizens Bank, N.A. v. Nash, No. 2:20-cv-00351 (E.D. Pa. 2021) a lien priority fight occurred between the IRS and the bank holding the taxpayer’s mortgage.  In many ways the bank’s problem reminded me of problems that routinely plague the IRS in lien priority fights.  The bank erroneously recorded a release and that

Even Within States, Tax Treatment Differs by Industry

TweetShareSharePin0 Shares Businesses’ tax liability can differ markedly across states, and policymakers often pay attention to this competitive tax landscape. What is less often remarked upon, however, is the variation of tax treatment within a given state. Different industries and activities can face radically different tax burdens within the same state due to non-neutralities in

2021 State Income Tax Cuts

TweetShareSharePin0 Shares Trend: States Reform Income Taxes To Provide Relief And Remain Competitive Key Findings As states close their books for fiscal year 2021, many have much more revenue on hand than they anticipated last year. In 2021, 11 states have enacted laws to reduce their income tax rates, with 10 reducing individual income tax

Incarcerated Individual Subject to Delinquency Penalties Even Though Attorney Embezzled Funds and Failed To File His Tax Returns

TweetShareSharePin0 Shares We have often discussed the reach of the 1985 Supreme Court case United States v. Boyle. Section 6651(a)(1) and (2) impose delinquency penalties for failing to file a tax return or pay a tax unless the taxpayer can establish that the failure was due to reasonable cause and not willful neglect.  Boyle essentially stands for
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