Trying to work out a client’s IRS issues these days can be frustrating for the client and the tax professional. You can’t throw a stone without hitting a story about delays and problems the IRS is having. I was recently...
When a taxpayer does not agree with tax adjustments proposed by an IRS examiner, the IRS sends the taxpayer a Notice of Deficiency, which gives a taxpayer 90 days to file a petition with the U.S. Tax Court to dispute the...
On July 26th, U.S. Tax Court Judge Lauber issued an opinion in George S. Harrington v. Commissioner, upholding the IRS’ determinations that the taxpayer fraudulently underreported his offshore income and the civil...
In previous blog posts I have discussed the late filing penalty and the reliance on a tax professional defense to the penalty. We discussed the reliance defense with respect to a late estate tax return (HERE) and (HERE) and...
These days it seems like the government taxes everything it can. While it is debatable whether or not that is true, there are a number of “hidden” taxes of which many taxpayers are unaware. Taxes on wagers and...
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