tax Archive

Deemed Offer Acceptance and IRS Notice 2006-68

TweetShareSharePin0 Shares I’ve been spending a lot of time and spilling a lot of virtual ink on how and when an Offer in Compromise may be “deemed” accepted by the service. This happens when the IRS fails to reject an Offer within 24 months after submission. It is, as far as I can tell, an

Sometimes, Taxes Are Okay | Tax Policy Center

TweetShareSharePin0 Shares Corporations are willing to pay a tax penalty for high executive compensation. The Wall Street Journal found (paywall) big corporations seem willing to pay a tax price to keep highly compensated executives happy. It found that 36 companies in the S&P 500 paid a combined $2.1 billion in taxes on nondeductible compensation over

When Does the Clock Stop?

TweetShareSharePin0 Shares It is pretty much a rite of passage for my students to file at least one Offer in Compromise for their clients. A lot of those Offers are presently accumulating dust in Brookhaven, New York. The length of inaction, as well as the precedential Tax Court case Brown v. Commissioner, has had me

Tax Preparer Gives Stunning Testimony In $200K Tax Fraud Case

TweetShareSharePin0 Shares Top New Orleans Parish District Attorney Jason Williams is facing federal charges for $200,000 in tax fraud. The former top prosecutor’s trial officially began with jury selection on Monday, July 18. Opening statements occurred on Tuesday, July 19, with Williams’s tax preparer, Henry Timothy, taking the stand on Wednesday, July 20.  Timothy delivered

IRS seeks transformation in new 5-year plan

TweetShareSharePin0 Shares Improving the taxpayer experience while surmounting operational difficulties that include a shrinking workforce are among goals the IRS has set for itself in the next five fiscal years. The 26-page IRS Strategic Plan FY 2022–2026 (Publication 3744) was released Wednesday, outlining strategic goals broadly for service, enforcement, people, and transformation. IRS Commissioner Chuck

Student Loan Forgiveness Tax Treatment Creates Confusion

TweetShareSharePin0 Shares Student debt forgiveness has been at the forefront of recent federal policy discussions, with President Biden exploring using executive action to cancel up to $10,000 in student loan debt per borrower. Under current law, the tax code handles debt forgiveness differently depending on the borrower’s repayment plan—canceling student loan debt would have new,

Pitfalls and Possibilities for “Aging Into” Offer Acceptance

TweetShareSharePin0 Shares As Keith posted, the Tax Court recently issued a precedential opinion discussing when an Offer in Compromise might “age” into default acceptance under IRC § 7122(f). As someone with numerous Offers that are nearing the two-year default mark, I read the opinion (Brown v. C.I.R., 158 T.C. No. 9 (2022)) closely.  And from those 13 pages, though there is essentially

A Climate Emergency, A Health-Only BBB, And Property Tax Woes

TweetShareSharePin0 Shares President Biden may declare a climate emergency, but what about clean energy tax credits? Biden may declare a national climate emergency today, which could allow him to take some steps to reduce carbon emissions through executive actions. But he can’t unilaterally expand tax subsidies or tax carbon emissions. Senate Finance Committee Chairman Ron

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