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Is the IRS Going to Contact Your Neighbor or Others? New IRS Notices Say They Intend to Do Just That
By on August 27, 2019
Many taxpayers have begun to receive a letter from the IRS stating that the IRS intends to contact other persons—including potentially the taxpayer's neighbors, banks, employers, and employees—about the taxpayer's tax liability.
The IRS Streamlined Procedures: Not For Everyone
By on August 27, 2019
The IRS Streamlined Procedures are not a one-size-fits-all program, as evidenced by the successful criminal indictment of a taxpayer charged with filing a false "streamlined submission" to disclose his foreign accounts and activities.
When Can the IRS Abate Interest?
By on August 19, 2019
Interest on a federal tax liability generally begins accruing from the date the tax should have been paid, even when the additional tax is due to IRS examination changes. IRC Section 6404 allows the IRS to abate interest under some specific circumstances, primarily unreasonable delay by the IRS in determining the taxpayer's tax liability.
A New Court Decision on E-Filed Tax Returns and the Failure to File Penalty
By on August 8, 2019
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.
The Importance of Hiring the Right Valuation Expert in an Estate Tax Case
By on August 6, 2019
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 The 9th Circuit's recent unpublished affirmation of the Tax Court's decision in Estate of Kollman v. Commissioner highlights the importance of vetting and hiring the right valuation expert.
Texas Comptroller Proposes Revisions to Texas Franchise Tax Rule 3.586, Implementing Wayfair
By on August 5, 2019
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).