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Get Compliant or Else: IRS Embarks on Letter Campaign to Reach 10,000 Virtual Currency Owners
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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.
The Hidden Dangers of Filing a Tax Court Petition
By on July 29, 2019
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!!"
Shifting the Burden of Proof to the IRS
By on July 17, 2019
In a prior blog post, I discussed the burden of proof in a tax controversy and how in most situations, the taxpayer has the burden of proof. In this post, I will discuss how a taxpayer can shift the burden of proof to the IRS. While the result of most cases does not turn on which party has the burden of proof, it is my experience that the willingness of IRS counsel to discuss a reasonable settlement increases if the IRS has the burden of proof.
