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 …
Tax Articles
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 make this showing. But what exactly is a competent tax professional? The court addressed this… Continue reading Penalty Abatement for Reliance on Tax Advisor Who Made Obvious Errors
Wholly Owned Corp and Parent Not the “Same Corporation” for Interest Netting
In Ford Motor Co. v. United States, No. 14-458T (Ct. Cl. 2017), the court addressed whether a wholly owned corporation and its parent were the “same corporation” when computing the amount of interest the taxpayer owed to the IRS. This …..
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Common IRS Collection Notices and What they Mean
Did you receive a notice from the IRS in the mail? If so, you either (1) opened it immediately as you had to know what the problem was or (2) refused to open it as you were hoping that the …
Wholly Owned Corp and Parent Not the “Same Corporation” for Interest Netting
In Ford Motor Co. v. United States, No. 14-458T (Ct. Cl. 2017), the court addressed whether a wholly owned corporation and its parent were the “same corporation” when computing the amount of interest the taxpayer owed to the IRS. This “same corporation” issue is one that comes up in most interest-netting cases. The Interest Netting… Continue reading Wholly Owned Corp and Parent Not the “Same Corporation” for Interest Netting
Electing Small Tax Case Treatment in U.S. Tax Court
Taxpayers often handle cases in the U.S. Tax Court by themselves. This is typically the first time the taxpayer has been involved in a court case and the taxpayers are not familiar with the rules or how a court case …
Court Says IRS Has Sufficient Info for R&D Tax Credit Sample Size
The court entered another order in the CRA Holdings U.S., Inc. v. United States, No. 15-CV-239W(F) (W.D.N.Y. 2017) case. The order addressed a dispute over the appropriate sample to be used to evaluate the taxpayer’s research tax credit. We previously …
Can I Transfer Assets to Another Person If I Owe the IRS?
Taxpayers often ask us whether they can transfer property to another person if they have an unpaid tax debt or they expect to have a tax debt they cannot pay. There are a number of rules that have to be …
Two Years to File Refund Suit in District Court, Six Years in Federal Court of Claims
If the IRS owes the taxpayer a refund, the general rule is that the taxpayer has to file a refund claim with the IRS, wait for the IRS to disallow the claim, and then, within two years of the date …..
The post Two Years to File Refund Suit in Distric…
Two Years to File Refund Suit in District Court, Six Years in Federal Court of Claims
If the IRS owes the taxpayer a refund, the general rule is that the taxpayer has to file a refund claim with the IRS, wait for the IRS to disallow the claim, and then, within two years of the date the claim is disallowed, file suit to recoup the refund. This is the general rule.… Continue reading Two Years to File Refund Suit in District Court, Six Years in Federal Court of Claims