subMenu
Archive by Month
Update on IRS Denial or Revocation of Passports
By on April 30, 2018
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.
Methods of Proof in a Criminal Tax Investigation
By on April 23, 2018
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.
Identifying a Taxpayer's Trades or Businesses for Purposes of §199A
By on April 13, 2018
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").
By on April 9, 2018
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.
