Resources Archive
June 18, 2020
Stress Testing the Estate Plan...
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In a previous blog post we discussed the Tax Court's recent decision in The Estate of Howard V. Moore v. Commissioner. An important take away from Moore for tax professionals and their clients is the importance of stress testing the estate planning to avoid being "low hanging fruit" for the IRS.
June 17, 2020
Things that Make You Go Hmmm: Tax Court Orders Partnership to Explain Over 480% Increase in Value in 3 Days to Avoid 40% Penalty in Conservation Easement Dispute...
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If Tax Court Judge Lauber's June 15, 2020 order is any indication, the Tax Court has grown tired of syndicated conservation easement cases.
June 16, 2020
A Tough Lesson About Estate Planning-The Estate of Howard V. Moore v. Commissioner...
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Earlier this year, the U.S. Tax Court in The Estate of Howard V. Moore v. Commissioner reminded every taxpayer that while estate planning is important, to achieve the intended estate tax benefits, traps must be avoided.
June 16, 2020
Debt Relief: Breaking Down the Tax Aspects of Covid-19's Economic Impact – Part III, Defining Indebtedness...
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Indebtedness has been a central focus of Parts I and II of this series, and it will continue to be a key concept in future posts as we explore in further detail the COD Income exceptions and discuss potential tax consequences resulting from modifications of indebtedness. In order to fully grasp the concepts discussed throughout this series, a baseline understanding of what the term "indebtedness" means is necessary. This Part III seeks to provide a brief introduction to the history of indebtedness in the tax law and serve as a guide to understanding what constitutes indebtedness.
June 16, 2020
Meadows Collier Monthly Webinar June 2020... [ read ]
June 15, 2020
*UPDATED* IRS HAS NOW ALSO EXTENDED DUE DATE AND PAYMENT DATE FOR GIFT AND GST TAX RETURNS, AS WELL AS ESTATE TAX RETURNS, AND ASSOCIATED TAX DUE, TO JULY 15, 2020....
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As mentioned in a previous blog post, IRS Notice 2020-18 provides an automatic extension of time to file income tax returns and pay federal income taxes until July 15, 2020 for Affected Taxpayers-defined as any person, including any individual, trust, estate, partnership, corporation, or other entity under IRC 7701(a)(1), with a federal income tax return or payment otherwise due on April 15, 2020.
June 8, 2020
IRS Called Out for Not Pursuing High Income Taxpayers...
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On May 29, 2020, the Treasury Inspector General for Tax Administration (TIGTA) issued a report entitled, "High-Income Nonfilers Owing Billions of Dollars Are Not Being Worked by the Internal Revenue Service". The report found that 879,415 high-income tastaxpayers failed to file tax returns from 2014-2016 resulting in approximately $45.7 billion in unpaid taxes. On June 4, 2020, the Senate Finance Committee Chairman, Chuck Grassley, sent a letter to IRS Commissioner, Charles Rettig, requesting information on how many tax dollars went uncollected and why there was so little effort to address the issue.
June 5, 2020
A District Court Pushes Back on Government's Willful FBAR Penalty...
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After a string of government victories in willful FBAR penalty cases, there may be some light at the end of the tunnel for taxpayers challenging an assertion of a willful FBAR penalty. In United States v. Sandra J. de Forrest , the U.S. District Court for the District of Nevada denied the government's motion for partial summary judgment regarding a willful FBAR penalty, finding there were genuine disputed material facts regarding the taxpayer's knowledge of the obligation to file an FBAR.
June 6, 2020
U.S. Tax Court Announces Trial Sessions will be Conducted Remotely...
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On May 29th, the U.S. Tax Court announced it will be conducting remote trial sessions until further notice, joining many other courts around the country.
May 29, 2020
Debt Relief: Breaking Down the Tax Aspects of Covid-19's Economic Impact - Part II...
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As discussed in Part I of this series, the cancellation of indebtedness, whether in whole or in part, generally results in COD Income to a taxpayer which must be included in gross income. Section 108 of the Internal Revenue Code (the "Code"), though, provides a handful of exceptions to this general rule of income inclusion. However, due to Covid-19, Congress has expanded exceptions to the general COD Income rule beyond those in section 108. Furthermore, it is possible, based on measures passed during prior economic crises, that Congress will pass additional exceptions to the general COD Income rule and that situations will arise in which COD Income exceptions may be expanded beyond their typical scope.
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