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Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P.

901 Main Street, Suite 3700
Dallas, TX 75202

Phone: (214) 744-3700
Fax: (214) 747-3732
Toll Free: (800) 451-0093

submit inquiry

Archive by Month

  • The Trust Fund Recovery Penalty

    By Joel N. Crouch on April 29, 2024

     

    A business that has employees is required by the Internal Revenue Code to withhold payroll taxes and income taxes from the wages of its employees and to pay those withheld amounts, called trust fund taxes, to the IRS.

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  • IRS Appeals Forms New Office to Help IRS Exam Resolve Disputes Earlier and Easier

    By Anthony P. Daddino on April 25, 2024

     

    For years, the IRS has offered alternative dispute resolution (ADR) at various stages of the tax administrative process. Use of ADR, however, has been declining in recent years. With this new office, IRS Appeals aims to make its ADR programs, such as Fast Track Settlement, Fast Track Mediation, Rapid Appeals Process and Post-Appeals Mediation, more attractive and accessible for eligible taxpayers. The new office will also pilot changes to those ADR programs.

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  • IRS and the Last Known Address Rule

    By Joel N. Crouch on April 20, 2024

     

    When the IRS issues a Notice of Deficiency (NOD), I.R.C. Sections 6212(a) and (b)(1) require that the NOD be sent to the taxpayer's "last known address" by certified or registered mail. The taxpayer's last known address is the address that appears on the most recently filed and processed tax return unless the taxpayer has given the IRS clear and concise notification of a different address. If the IRS has properly mailed the NOD to the taxpayer's last known address and the taxpayer fails to file a petition with the Tax Court within 90 days, the IRS will assess the tax and penalties included in the NOD. Thereafter, the IRS contacts the taxpayer and begins collection activities.

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  • Reliance on Professional Advice Defense to IRS Penalties

    By Joel N. Crouch on April 17, 2024

     

    When the IRS proposes changes to a taxpayer's return that result in an underpayment of tax, it will always consider penalties under Internal Revenue Code Section 6662 - Imposition of Accuracy-Related Penalty on Underpayments. The most common penalties proposed by the IRS are negligence and substantial understatement of income tax, both of which are 20% of the tax due.

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  • IRS Caps Off its 2024 Dirty Dozen List with an "Everything Else" Approach

    By Anthony P. Daddino on April 11, 2024

     

    In grand finale style, the IRS released its last entry to its 2024 Dirty Dozen List with a catch-all listing of transactions and invitation to taxpayers to be a whistleblower.

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  • IRS Proposes Adding Certain CRATs to the Naughty List

    By Joel N. Crouch on April 8, 2024

     

    After a period of relative inactivity, over the last 18 months the IRS has increased the number of potential listed transactions including syndicated conservation easements, micro-captives, Malta pension plans and monetized installment plans. Most of these were already on the IRS Dirty Dozen list, but, so far, none of the proposed regulations regarding making these listed transactions have been finalized.

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  • Hobby Loss and Ranches – An Overview of Section 183

    By Mary E. Wood, Josh O. Ungerman on April 5, 2024

       

    If a taxpayer undertakes an activity with the objective of making a profit, the expenses related to the activity are generally deductible and any excess losses related to the activity can be utilized in future tax years (subject to applicable net operating loss limitations). If the activity is deemed to be subject to the "hobby loss rules" of Internal Revenue Code Section 183, however, the expenses and losses related to the activity are generally disallowed. Much to the chagrin of taxpayers in farm and ranching businesses, the IRS often comes in after the fact in an examination and makes a determination that the farm and ranching activity is not engaged in for profit and, thus, subject to the punitive hobby loss limitations. A well thought out and thorough challenge to an IRS examination is imperative.

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Contact Us

Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P.

901 Main Street, Suite 3700
Dallas, TX 75202

Phone: (214) 744-3700
Fax: (214) 747-3732
Toll Free: (800) 451-0093