Resources Archive
August 10, 2021
Tax Court Petitions and Premature Assessment...
[ read ]
When a taxpayer does not agree with tax adjustments proposed by an IRS examiner, the IRS sends the taxpayer a Notice of Deficiency, which gives a taxpayer 90 days to file a petition with the U.S. Tax Court to dispute the proposed adjustments. If the taxpayer files a timely petition, the IRS cannot assess the proposed tax until the case is resolved by the U.S. Tax Court. If a taxpayer does not file a tax court petition, the IRS assesses the tax and the taxpayer is contacted by the IRS collection division for payment.
August 4, 2021
IRS Statute of Limitations and Civil Fraud...
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On July 26th, U.S. Tax Court Judge Lauber issued an opinion in George S. Harrington v. Commissioner, upholding the IRS' determinations that the taxpayer fraudulently underreported his offshore income and the civil fraud penalty applied. There is nothing particularly unique about the case but it includes a very good discussion of the factors the court will consider when the IRS proposes a civil fraud penalty and the resulting impact on the statute of limitations.
July 29, 2021
Taxpayer's Penalty Defense Gets Boyled (Boiled?)...
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In previous blog posts I have discussed the late filing penalty and the reliance on a tax professional defense to the penalty. We discussed the reliance defense with respect to a late estate tax return and with respect to late e-filed returns .
July 27, 2021
Are You Feeling Lucky? IRS Taxes on Wagers and Bookmakers...
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These days it seems like the government taxes everything it can. While it is debatable whether or not that is true, there are a number of "hidden" taxes of which many taxpayers are unaware. Taxes on wagers and occupational taxes on bookmakers are a couple of those "hidden" taxes. Although the casinos in Las Vegas know about and pay these taxes, illegal bookmakers may not be and could be facing significant tax liabilities as a result.
July 26, 2021
Is There Still Hope for Taxpayers? Another Court Determines Previous IRS Guidance Limiting FBAR Penalty is Invalid...
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On July 13, 2021, the Second Circuit issued an opinion in United States v. Kahn, No. 19-3920 (2d Cir. 2021) affirming the trial court's grant of summary judgment against the defendants for FBAR penalties, plus statutory additions and interest, in the amount of $4,264,728.
July 22, 2021
2022 Texas Bankers Association Graduate Trust Schools... [ read ]
June 30, 2021
Recent Legislation Gives Taxpayers Greater Access to District Court in Challenging the Texas Comptroller's Denial of a Refund Claim or Assessment of Tax...
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Among the various bills that became law in the 87th Texas Legislature of 2021 are two amendments to the Texas Tax Code that will significantly impact the procedures available for challenging the denial of tax refund claims and assessments by the Texas Comptroller of Public Accounts in district court. Both of these bills (SB 903 and HB 2080) are intended to make district court more accessible to taxpayers.
June 28, 2021
Keller Williams Real Estate... [ read ]
June 22, 2021
ACPEN-Estate and Gift Tax Alert... [ read ]
June 22, 2021
(MPMG) Metroplex Practice Management Group... [ read ]
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