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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

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By Joel N. Crouch on April 8, 2024

IRS Proposes Adding Certain CRATs to the Naughty List... [ read ]

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.

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

Hobby Loss and Ranches – An Overview of Section 183... [ read ]

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.

By Anthony P. Daddino on March 20, 2024

The Clock is Ticking: IRS Identifies Seven (7) ERC Warning Signs in Advance of March 22nd deadline for IRS' Voluntary Disclosure Program... [ read ]

For those procrastinating, or just discerning, taxpayers that are still considering the IRS' disclosure program for employee retention credit (ERC) claims, the IRS released today seven potential red flags to help taxpayers make a decision before the program closes on March 22, 2024.

By Joel N. Crouch on March 11, 2024

Deadline for ERC Voluntary Disclosure is Around the Corner... [ read ]

Blog readers are well aware of the IRS continuing enforcement efforts regarding the Employer Retention Credit (ERC). One tool in that enforcement effort is the ERC voluntary disclosure program for employers who received questionable ERC refunds. Introduced on December 22, 2024, the deadline for applying, March 22, 2024, is fast approaching. Any employer who has concerns about an ERC refund should consult with a competent tax advisor as soon as possible about whether they should be considering a voluntary disclosure.

By Jeffrey M. Glassman on February 29, 2024

IRS Launches New Effort at High Income Non-Filers: Impacted Taxpayers Should Seek Representation... [ read ]

On February 29, 2024, the IRS announced a new effort to target high-income individuals. This time the IRS announced that they have opened 125,000 cases focusing on millionaires who have failed to file income tax returns. The IRS believes that, based on third-party information received, there may be more than $100 billion of unreported financial activity and conservatively hundreds of millions of dollars of unpaid tax.

By Joel N. Crouch on February 27, 2024

The Most Important Elements of a Successful IRS Voluntary Disclosure? Timing and Luck.... [ read ]

As in comedy, the most important element in an IRS voluntary disclosure is generally timing. However, a couple of U.S. Tax Court memorandum opinions in Whistleblower 14376-16W v. Commissioner, T.C. Memo 2017-181 and T.C. Memo 2024-22, point out that timing and luck are the most important elements of a voluntary disclosure

By Joel N. Crouch on February 23, 2024

Another Shot Across the ERC Bow by the IRS... [ read ]

One of my ERC friends sent me the IRS letter below that was received by one of his ERC clients about their ERC filing. The letter, Notice CP271, says there has been aggressive advertising involving ERC and the employer should confirm they are entitled to the ERC amount they claimed.

By Joel N. Crouch on February 21, 2024

Return Preparer Fraud Results in Harsh Outcome for Innocent Taxpayer... [ read ]

the IRS generally has three years to assess additional tax, pursuant to IRC Section 6501. The three years can be extended by agreement, the taxpayer filing for bankruptcy, the IRS issuing a Notice of Deficiency, or taxpayer involvement in a third party summons enforcement action.

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