The IRS has quite a few powers to encourage taxpayers to cooperate. The IRS summons is arguably the most powerful tool the IRS has in its arsenal. While the taxpayer may not agree that the underlying tax is even owed, they still have to comply with the IRS’s summons. The recent United States v. Battle,… Continue reading About the IRS Summons Enforcement Hearing
Tax Articles
New IRS Tax Lien Regulations Issued
The dreaded IRS tax lien. Once filed, it can wreak havoc on credit scores. It can call into question occupational licenses. Worse yet, it triggers a flood of mail and phone calls from tax resolution companies hawking their services. About Liens and IRS Liens A tax lien is a claim to property. Think of it… Continue reading New IRS Tax Lien Regulations Issued
U.S. Tax Court Stipulations are Binding
Details matter when it comes to tax litigation. This is especially true for cases before the U.S. Tax Court given its unique stipulation or agreement process. The Mathia v. Commissioner, No. 10-9004 (10th Cir. 2012) case provides a prime example of this. The Facts & Procedural History Mathia was a 8% limited partner in Greenwich Associates.… Continue reading U.S. Tax Court Stipulations are Binding
IRS Interest on Employment Taxes Can be Problematic
Interest imposed by the IRS on tax debts can be problematic, as is highlighted by the recent Scanlon White, Inc. v. Commissioner case. Scanlon White Case In Scanlon White, the IRS took four years to deny the taxpayer’s offer in compromise for its unpaid employment tax liability. The taxpayer requested that the IRS abate the… Continue reading IRS Interest on Employment Taxes Can be Problematic
Taxation of Employer Provided Education: A Look At Section 127 Plans
During a recent conversation that I had with another tax blogger, I commented about how many taxpayers fail to take advantage of Section 127 plans. This comment came up in a very brief mention of how Congress recently frustrated the tax plan of many parents who are saving for their children’s college education, by extending… Continue reading Taxation of Employer Provided Education: A Look At Section 127 Plans
Congress Works on the IRS Informants Reward Program
The Tax Relief and Health Care Act of 2006 provides a lot of new tax procedure provisions, such as the Section 6702 frivolous “tax submissions” penalty. This Act also set out a number of changes related to the ineffective and poorly administered (according to the U.S. Treasury Inspector General for Tax Administration) IRS informants reward… Continue reading Congress Works on the IRS Informants Reward Program
The Improved Frivolous Return Penalty
The tax penalty for filing a frivolous income tax return has been set so low and its reach so limited that the penalty has not been of much concern to taxpayers. Unfortunately, those days are now gone. The Tax Relief and Health Care Act of 2006 has made sweeping changes to the Section 6702 frivolous… Continue reading The Improved Frivolous Return Penalty
Taxpayers Cannot Record IRS Telephone Interviews in CDP Hearings
Sometimes it is nice to have a record of what transpired. This is true even if the recording is never used. Just the fact that the recording is being made, and everyone is aware that it is being made, can change the tone and substance of the meeting. The law allows taxpayers to record meetings… Continue reading Taxpayers Cannot Record IRS Telephone Interviews in CDP Hearings
Taxing Online Video Game Earnings
I came across this very interesting article about taxing online video game transactions. This type of issue does show the flaw or challenge presented by a tax system that is dependent upon the concept of “income” and the problem is likely to become a much more serious problem for the US Treasury. It is now… Continue reading Taxing Online Video Game Earnings
Tax Protestor has Constitutional Right to Choose his Tax Attorney
Okay United States v. Nolen is yet another fascinating case (this case will probably make it into the criminal procedure books used in law schools). Nolen addresses the issue as to whether a tax protester has a Sixth Amendment right to choose his own attorney, even if the attorney, unfortunately, insults the court. Facts &… Continue reading Tax Protestor has Constitutional Right to Choose his Tax Attorney