Resources Archive
July 8, 2016
IRS Administrative Summons to a Third Party: The Recipient's and Taxpayer's Duties and Rights...
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In a previous blog post, I discussed the duties and rights of a taxpayer who receives an IRS administrative summons for records or testimony. In this blog post, I will discuss the duties and rights of a third party who receives an IRS summons for records or testimony and the taxpayer's right and duties with regard to a third party summons.
July 6, 2016
IRS Administrative Summons to a Taxpayer: The Taxpayer's Duties and Rights...
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In most IRS examinations, the taxpayer and the IRS prefer an informal information-gathering process with the IRS issuing Information Document Requests (IDRs) and the taxpayer providing responses. However, there are circumstances where the issuance of an IRS administrative summons to the taxpayer for documents and/or testimony becomes necessary. When the IRS issues an administrative summons, it is very important that the taxpayer and the taxpayers' representative understand the taxpayer's duties and rights in responding.
June 30, 2016
IRS Announces Procedure for Seeking a Return of Property Seized in Legally Sourced Structuring Cases...
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On June 16, 2016, the IRS announced a new procedure for taxpayers who have had their property seized to file a petition for remission or mitigation. The IRS has identified more than 700 taxpayers that it believes may qualify, and the IRS has been notifying these taxpayers by mail over the past month.
June 28, 2016
Metroplex Practice Management Group - Dallas... [ read ]
June 24, 2016
TSCPA Accounting in Agriculture Web-Conference... [ read ]
June 17, 2016
IRS Enforcement Update Panel... [ read ]
June 15, 2016
CPE by the Sea... [ read ]
June 14, 2016
Tax Alliance Conference... [ read ]
June 9, 2016
Explosions Continue in the Minefield that is IRA-Owned Businesses...
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So far in 2016 we have seen two Tax Court decisions dealing with IRA-owned businesses. In Polowniak v. Comm'r, decided on February 25th, the Tax Court dealt with a purported run-around of contributions limits. Mr. Polowniak owned and operated through an S corporation a successful consulting business. In an effort to siphon some of those consulting fees to a tax-advantaged vehicle, Mr. Polowniak set up a new company and Roth IRA and immediately directed the Roth IRA to acquire virtually all of the new company stock.
June 9, 2016
Abracadabra! The IRS Proposes Rules that Bring into Plain View U.S. Disregarded Entities with Foreign Owners...
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The IRS is seeking to shine the light on domestic disregarded entities with foreign owners. Under regulations proposed last month, a U.S. disregarded entity that is wholly owned by a foreign person would be treated as a domestic corporation separate from its owner for reporting and record maintenance requirements under IRC Section 6038A.
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