Resources Archive
July 14, 2022
Certain Estates Now Have Five Years to Make a Portability Election...
[ read ]
On Friday, July 8, 2022, the IRS released Revenue Procedure 2022-32, which supersedes Revenue Procedure 2017-34 and extends the period of time certain estates have to make a "portability" election under IRC § 2010(c)(5)(A). A portability election allows for a surviving spouse to utilize the deceased spouse's unused exclusion amount (DSUE). The portability election may only be made on a timely filed federal estate tax return (Form 706).
July 12, 2022
July Meadows Collier Monthly Webinar... [ read ]
June 27, 2022
Thinking of Calling the IRS? Good Luck....
[ read ]
The National Taxpayer Advocate Service (TAS) recently issued its annual report to Congress. One of the more troubling findings in the report was that during the 2022 filing season, the IRS received 73 million calls and only 7.5 million of those calls were answered by an IRS employee. Another interesting side note was that in 2021, the IRS received 167 million calls and only 9% of those calls were answered by an IRS employee.
June 24, 2022
14th Annual NYU Tax Controversy Forum... [ read ]
June 22, 2022
Cryptocurrency: A Tax and Estate Planning Perspective... [ read ]
June 15, 2022
Congress May Soon Overrule the IRS on Crypto Taxation; What Should Taxpayers Do?...
[ read ]
Earlier this year, I wrote about Jarrett v. United States, No. 3:21-cv-00419 (M.D. Tenn.), a case in which a crypto taxpayer rejected a complete government concession of a lawsuit. At issue in the case was whether the taxpayer's cryptocurrency staking rewards were immediately taxable. Presumably, the taxpayer was motivated by a desire to have a court publicly address the issue—which still has not occurred. To this date, there is no clear rule—let alone a clear signal from the IRS about how it views the issue—that dictates whether staking rewards are or are not immediately taxable.
June 14, 2022
June 2022 Meadows Collier Free 1-Hour Monthly Webinar... [ read ]
June 8, 2022
Part Two: Are Tax Returns Given to an IRS Agent Considered Filed?...
[ read ]
In 2015, I wrote a blog post with this same title (here) concluding that based on case law, a tax return that is given to a representative of the IRS is not considered filed and, therefore, the statute of limitations does not start. I followed that up with a blog post (here) last year discussing a case which confirmed that tax returns are not considered filed if merely given to an IRS representative. Furthermore, in 2015 the 9th Circuit reversed a CPA's convictions for tax evasion because "filing" is an element of tax evasion and the CPA handed his fraudulent tax returns to the IRS agent instead of filing them. United States v. Boitano
June 7- 9, 2022
2022 Tax Alliance Conference... [ read ]
June 2, 2022
Jeffrey Glassman Named 2022 John S. Nolan Fellow... [ read ]
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