Resources Archive
August 16, 2019
TXCPA Advanced Estate Planning Conference... [ read ]
August 8, 2019
IRS Nationwide Tax Forum... [ read ]
August 8, 2019
A New Court Decision on E-Filed Tax Returns and the Failure to File Penalty...
[ read ]
In prior blog posts, I discussed the application of the IRC Section 6651 failure-to-file penalty to an electronically-filed tax return. On August 2nd, a U.S. District Court in Tennessee took on the issue directly and ruled against a taxpayer holding that the U.S. Supreme Court decision in United States v. Boyle is applicable even when the tax return is filed electronically.
August 6, 2019
The Importance of Hiring the Right Valuation Expert in an Estate Tax Case...
[ read ]
Expert testimony in litigation is very important. It is even more important in an estate tax case where the only issue is the value of the decedent's assets and the case will likely turn on valuation expert testimony. The 9th Circuit's recent unpublished affirmation of the Tax Court's decision in Estate of Kollman v. Commissioner highlights the importance of vetting and hiring the right valuation expert.
August 5, 2019
Texas Comptroller Proposes Revisions to Texas Franchise Tax Rule 3.586, Implementing Wayfair...
[ read ]
The Texas Comptroller's office issued a draft set of proposed revisions to Comptroller Rule 3.586 (Margin: Nexus) today in response to the U.S. Supreme Court's decision last year in South Dakota v. Wayfair, Inc., 138 S.Ct. 2080 (2018).
August 5, 2019
Virtual Currency Holders Should Be Seeking Legal Counsel as IRS Begins Issuing Warning Letters...
[ read ]
In their article published by TXCPA entitled "Virtual Currency Holders Should Be Seeking Legal Counsel as IRS Begins Issuing Warning Letters," David Colmenero and Anthony Daddino explore the IRS' latest installment in its enforcement initiative against virtual currency: the issuance of warning letters to more than 10.000 cryptocurrency holders. Please click here to read the article.
August 1, 2019
Stakes Rising in Litigation of Non-Willful FBAR Violations...
[ read ]
Josh Ungerman was quoted in the Tax Notes article, "Stakes Rising in Litigation of Non-Willful FBAR Violations." This article discusses whether the IRS can impose over $2.7 million in FBAR penalties for non-willful failure to file FBARs as opposed to a maximum penalty of $10,000 per year.
August 1-2, 2019
TexasBarCLE 37th Annual Advanced Tax Law Course cosponsored by the Tax Section of the State Bar of Texas... [ read ]
July 29, 2019
Get Compliant or Else: IRS Embarks on Letter Campaign to Reach 10,000 Virtual Currency Owners...
[ read ]
The Internal Revenue Service has begun sending letters to taxpayers with virtual currency transactions that potentially failed to report income and pay the resulting tax from those transactions or did not report them properly. This is yet another step in the IRS' enforcement campaign against virtual currency.
July 29, 2019
The Hidden Dangers of Filing a Tax Court Petition...
[ read ]
When the IRS examines a tax return and proposes adjustments, it will send a Notice of Deficiency to the taxpayer setting forth the adjustments. A taxpayer who disagrees with the Notice of Deficiency may file a petition with the U.S. Tax Court disputing the IRS proposed adjustments without first paying the resulting tax, penalties and interest. Although this seems a like a simple and economical means for disputing IRS examination adjustments, as former football coach and current ESPN commentator Lee Corso says, "Not so fast my friend!!"
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