If you have an ongoing dispute with the IRS for one or more years and the outcome of that dispute will impact the current year, can you take a wait and see approach to filing the current year tax return? …
Category: Houston Tax Attorney Blog
U.S. Taxpayer With U.S. Residence Cannot Exclude Foreign-Earned Income
There are a number of tax issues that U.S. citizens and residents who live abroad have to consider. One of these is whether they qualify to exclude their foreign-earned income in computing U.S. income taxes. This exclusion has resulted in …
When Forged Signatures Suffice: The Tacit Consent Exception
A tax return has to be signed to be valid. But what if the return is signed by someone else? Is a tax return with a forged signature a valid tax return? The court addressed this in Coggin v. United …
Court Says No Legal Right to IRS Appeals Review
Does the Taxpayer Bill of Rights create a legal right to have a tax dispute considered by the IRS Office of Appeals? The court recently addressed this question in Facebook, Inc. v. Internal Revenue Service, No. 17-cv-06490-LB (N.D. Calif. 2018), concl…
Settlement Award for Discrimination Related to Physical Injuries is Taxable
Damage awards received on account of personal physical injuries or physical sickness are not taxable. If a taxpayer receives a non-taxable award under this rule and then is discriminated against by his employer due to the physical injuries, is a …
Penalty Abatement for Reliance on Tax Advisor Who Made Obvious Errors
The IRS often willing to abate or remove tax penalties. To do so, taxpayers usually have to show that they acted with reasonable cause and in good faith. Relying on a competent tax professional can be one way taxpayers can …