Still waiting on the IRS to respond to your FOIA request? Well, according to a recent Government update, you may be waiting a while longer. As background, the Freedom of Information Act, 5 U.S.C. 552, provides any person the...
When it comes to settlement programs, the IRS is reminiscent of the South Park character Cartman, who demands that everyone “Respect my Authoritah!” Historically taxpayers participating in IRS settlement programs were at...
A recently filed Tax Court case has revealed just how much disdain the IRS has for microcaptives. And it is a lot. The case is SCC Holding Company of Pinellas, Inc. v. Commissioner, Docket No. 16285-22, filed in...
Our wealth transfer tax system provides taxpayers with exclusions from certain taxes. These exemptions are adjusted annually; the amount of the adjustment is tied to the Consumer Price Index. Last month, I wrote a blog...
During my career, I have assisted a number of taxpayers who have inadvertently terminated an S-Corporation election. Historically, fixing an inadvertent termination has been time consuming and expensive. The IRS fee for a...
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