If you have and IRS dispute brewing and you have not been able to resolve the matter with the IRS, you are probably going to have to ask the IRS Office of Appeals to consider the case. The IRS Office …
Tax Articles
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 …
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 second award paid by the employer also non-taxable? The court recently addressed this in Rajcoomar… Continue reading Settlement Award for Discrimination Related to Physical Injuries is Taxable
Court Says Serial IRS Whistleblower Claimant Cannot Remain Anonymous
In Whistleblower 14377-16W v. Commissioner, 148 T.C. 25, the U.S. Tax Court concluded that a whistleblower claimant could not remain anonymous when litigating his claim in court. This case is one all whistleblowers should read and fully understand as i…
Serial IRS Whistleblower Cannot Remain Anonymous
You would think that an IRS whistleblower could always remain anonymous. That is a fundamental feature of the whistleblower program. In Whistleblower 14377-16W v. Commissioner, 148 T.C. 25, the U.S. Tax Court concluded that a whistleblower claimant could not remain anonymous when litigating his claim in court. This case is one all whistleblowers should read… Continue reading Serial IRS Whistleblower Cannot Remain Anonymous
Tax Law is Not Determined by Reference to Common Term Used in the Industry
Just because businesses in a particular industry commonly use a term to describe a particular transaction or event, the industry term does not necessarily have any bearing on the Federal income tax consequences of the transaction or event. The court …..
Tax Law is Not Determined by Common Industry Term
Just because businesses in a particular industry commonly use a term to describe a particular transaction or event, the industry term does not necessarily have any bearing on the Federal income tax consequences of the transaction or event. The court addresses this in Greenteam Materials Recovery Facility PN v. Commissioner, T.C. Memo. 2017-122, in the… Continue reading Tax Law is Not Determined by Common Industry Term
Issue for the New Partnership Audit Procedures Raised in TEFRA Case
The Tax Equity and Fiscal Responsibility Act of 1982 (“TEFRA”) procedures were intended to make it easier for the IRS to audit partnership tax returns. TEFRA failed to deliver. The rules are nuanced and hard to apply. The new partnership …..
The post Issue for the New Partnership Audit Procedures Raised in TEFRA Case appeared first on Houston Tax Attorney.
Issue for the New Partnership Audit Procedures Raised in TEFRA Case
The Tax Equity and Fiscal Responsibility Act of 1982 (“TEFRA”) procedures were intended to make it easier for the IRS to audit partnership tax returns. TEFRA failed to deliver. The rules are nuanced and hard to apply. The new partnership audit procedures are intended to remedy this. With the new partnership IRS audit procedures coming… Continue reading Issue for the New Partnership Audit Procedures Raised in TEFRA Case
About the IRS’s Whistleblower Program
The IRS has the ability to pay you for information leading to the recovery of unpaid taxes. The payouts from the IRS’s “whistleblower” program can be significant. The payout can be up to 30 percent of the tax, penalties, and …