Resources Archive
January 22, 2020
PLR Update: IRS Issues its "No Ruling" List for 2020 as well as Extends a Surprising Invitation for PLR Requests in a Hot Button Area...
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In a previous blog post, I outlined the IRS private letter ruling process, including the mechanics of making a request and tips for presenting your ruling request to the IRS. In this blog post, I touch on the IRS' "no ruling" lists issued this month as well as discuss a strange invitation by the IRS for taxpayers to use the private letter ruling process to seek guidance on …. wait for it….. cryptocurrency taxation.
January 22, 2020
Another Arrow in the Taxpayer's Quiver against Trust Fund Penalties: Supervisory Approval...
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We all know that the IRS is quick to pull the trigger on penalties, especially trust fund penalties, which the IRS rightfully views as Uncle Sam's money. But the Tax Court's January 21st decision in Chadwick vs. Commissioner makes clear that even trust fund penalties must be approved by a supervisor when proposed; otherwise, the penalties are invalid.
Januray 20, 2020
Update on IRS Civil Enforcement Priorities...
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Last week, I participated in a conference call with IRS officials from Examination and Collection who were discussing the IRS' 2020 enforcement priorities. Here are the take-aways from the call.
January 13, 2020
Surprise, Surprise, An Estate Has Reasonable Cause For Filing A Tax Return Late...
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In prior blog posts we have discussed the uphill battle an estate faces when it requests abatement of a late filing penalty when the Form 706, United States Estate Tax Return, is not timely filed. Although there are cases where an estate has prevailed on a reasonable cause/reliance defense, they are few and far between. In the typical case, the court cites United States v. Boyle in holding that a taxpayer can rely on a tax professional for tax advice, but not regarding the "ministerial act" of filing a tax return on time.
January 6, 2020
IRS Coming After Tax-Delinquent Wealthy People in 2020...
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At recent tax programs, IRS officials referenced a new program called "Hi-Def" which will be targeting wealthy people who have not filed tax returns. The program is intended to address the perception that the IRS does not pursue delinquent wealthy people.
January 2, 2020
Appraiser Accuses IRS, DOJ of Violating Taxpayer Privacy Rules...
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Josh Ungerman was quoted in the article, "Appraiser Accuses IRS, DOJ of Violating Taxpayer Privacy Rules."
December 18, 2019
Fort Worth Chapter/TXCPA December Member Lunch and Learn... [ read ]
December 16, 2019
Happy Holidays from Meadows Collier!...
December 13, 2019
TXCPA 2019 CPE Expo - Irving... [ read ]
December 13, 2019
2019 Louisiana Tax Conference... [ read ]
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