I know what you are thinking: I can’t count letters. But the truth is far worse. The IRS used the five-letter “F” word: Fraud. The IRS recently released an IRS attorney memorandum addressing the...
Category: Blog
Amended Tax Return or Superseding Tax Return?
I recently had one of those “aha” moments and thought it was blog-post worthy. A tax return preparer called me after a tax return he tried to electronically file was rejected by the IRS because a return had already been...
IRS Stands Firm on Microcaptive Settlement Terms and Warns of Similar Treatment for Variations
Lest we forget the IRS’ position on microcaptives, yesterday the IRS issued a reminder to taxpayers that they should consult an “independent tax advisor” to size-up their captive insurance planning because “any future...
IRS Has Requested Comments on Ending Revenue Procedure 94-69 Disclosures As a Defense to Penalties
On August 19, 2020 the IRS requested comments on whether it should eliminate disclosures made under Revenue Procedure 94-69, which allows taxpayers to avoid accuracy-related penalties with respect to self-reported adjustments...
COVID Crisis Prompting the Need for a Private Letter Ruling in a Flash? No Problem.
Is COVID to blame for you missing a tax election, inadvertently terminating an election, or making the wrong election? Do you need immediate IRS attention… during a global pandemic when most IRS offices are closed? Don’t...