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By on Januray 27, 2020
On January 23rd the Joint Chiefs of Global Tax Enforcement (J5) released the following statement regarding its "day of action" conducted on January 22nd.
By on January 22, 2020
In a previous blog post, I outlined the IRS private letter ruling process, including the mechanics of making a request and tips for presenting your ruling request to the IRS. In this blog post, I touch on the IRS' "no ruling" lists issued this month as well as discuss a strange invitation by the IRS for taxpayers to use the private letter ruling process to seek guidance on …. wait for it….. cryptocurrency taxation.
Another Arrow in the Taxpayer's Quiver against Trust Fund Penalties: Supervisory Approval
By on January 22, 2020
We all know that the IRS is quick to pull the trigger on penalties, especially trust fund penalties, which the IRS rightfully views as Uncle Sam's money. But the Tax Court's January 21st decision in Chadwick vs. Commissioner makes clear that even trust fund penalties must be approved by a supervisor when proposed; otherwise, the penalties are invalid.
Update on IRS Civil Enforcement Priorities
By on Januray 20, 2020
Last week, I participated in a conference call with IRS officials from Examination and Collection who were discussing the IRS' 2020 enforcement priorities. Here are the take-aways from the call.
Surprise, Surprise, An Estate Has Reasonable Cause For Filing A Tax Return Late
By on January 13, 2020
In prior blog posts we have discussed the uphill battle an estate faces when it requests abatement of a late filing penalty when the Form 706, United States Estate Tax Return, is not timely filed. Although there are cases where an estate has prevailed on a reasonable cause/reliance defense, they are few and far between. In the typical case, the court cites United States v. Boyle in holding that a taxpayer can rely on a tax professional for tax advice, but not regarding the "ministerial act" of filing a tax return on time.
IRS Coming After Tax-Delinquent Wealthy People in 2020
By on January 6, 2020
At recent tax programs, IRS officials referenced a new program called "Hi-Def" which will be targeting wealthy people who have not filed tax returns. The program is intended to address the perception that the IRS does not pursue delinquent wealthy people.