Resources Archive
May 1, 2018
Texas Comptroller Implements a "Tax Amnesty Program," But Is This the Best Option for All Taxpayers?...
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Starting today, May 1, 2018 through June 29, 2018, the State of Texas Comptroller's Office will run its "Texas Tax Amnesty Program" which offers relief from tax-related penalties and interest for certain taxpayers. But before participating in that program, taxpayers may want to consider whether the Comptroller's existing voluntary disclosure program provides a better option for them.
April 30, 2018
Update on IRS Denial or Revocation of Passports...
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In a prior blog post we discussed IRC Section 7345 which allows the IRS to take actions to either revoke or deny a passport to a taxpayer with a seriously delinquent tax debt. On April 5, IRS Chief Counsel issued Notice CC-2018-005 which provides guidance for Chief Counsel attorneys regarding how to handle a lawsuit brought by a taxpayer in U.S. Tax Court pursuant to Section 7345(e). This notice was issued on the heels of IRS Deputy Chief Counsel Drita Tunuzi stating at a recent ABA Tax Section meeting that the IRS would probably start issuing the notices of passport revocation or denial by the end of February.
April 30. 2018
Amarillo Area Estate Planning Council... [ read ]
April 30, 2018
Lorman Education Services... [ read ]
April 27, 2018
Bloomberg Law Quote... [ read ]
April 23, 2018
"Group Still Pushing to Move CI to Treasury"... [ read ]
April 23, 2018
Methods of Proof in a Criminal Tax Investigation...
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In a criminal tax investigation, the IRS generally must prove a taxpayer either underreported his income or overstated his deductions. To do so the IRS uses a number of methods of proof that fall under one of two categories: Direct (Specific Items) Method of Proof or Indirect Methods of Proof.
April 13, 2018
Identifying a Taxpayer's Trades or Businesses for Purposes of §199A...
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At the heart of the new §199A deduction is a series of tentative deductions separately determined for each trade or business in which the taxpayer owns an interest based on 20% of qualified business income ("QBI").
April 6, 2018
IRS, DOJ Must Rethink Strategy on Felony Tax Obstruction Charges Post-Marinello... [ read ]
April 9, 2018
What Is A Kovel Accountant?...
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An attorney who represents a client in a criminal tax investigation will typically retain a forensic accountant to review and analyze the client's financial records and tax returns mirroring the work of the IRS criminal investigators. The accountant is generally referred to as a "Kovel Accountant" and is hired by the attorney, not the client, so that the accountant's work is protected by the attorney-client privilege.
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