Bankruptcy can be a great way to get rid of older tax debts. The bankruptcy process is supposed to provide a fresh start. The In re Christensen, 15-29773, 15-29783 (2016 Bankr. D. Utah), case is an example where the IRS attempted to use the bankruptcy process not to provide a fresh start, but to collect […]
The post Bankruptcy Court Rejects IRS Plan to Sell Residence appeared first on Houston Tax Attorney.
Bankruptcy can be a great way to get rid of older tax debts. The bankruptcy process is supposed to provide a fresh start. The In re Christensen, 15-29773, 15-29783 (2016 Bankr. D. Utah), case is an example where the IRS attempted to use the bankruptcy process not to provide a fresh start, but to collect… Continue reading Bankruptcy Court Rejects IRS Plan to Sell Residence
The IRS issued CCA 201650012, which addresses the rules for internal use software (“IUS”) prior to the issuance of the final IUS regulations. The guidance considers whether a taxpayer can apply some or must apply all of the rules in the prior IUS…
If a sole proprietor is able to deduct an expense he incurred in the year he died for property that was not used up in the year he died, must his estate then report the amount as income in the following year for the amount of taxes saved by the deduction in the prior year? […]
The post Tax Benefit Rule Does Not Apply to Transfers at Death appeared first on Houston Tax Attorney.
A sole proprietor incurred a business expense. He dies in the same year. The business expense was for property that would last more than one year. Does the business owner’s estate have to report the amount of the deduction as income? This question is answered by considering the tax benefit rule. The court addressed this… Continue reading Tax Benefit Rule & Transfers at Death
Taxpayers who are assessed trust fund recovery penalties need to take note of the U.S. Tax Court’s recent decision in Anderson v. Commissioner, T.C. Memo. 2016-219. The decision highlights a potential foot fault they may make when trying to resolve their trust fund recovery penalties at the IRS administrative level. Facts and Procedural History The […]
The post Preserving Judicial Review for Trust Fund Recovery Penalties appeared first on Houston Tax Attorney.
Taxpayers who are assessed trust fund recovery penalties need to take note of the U.S. Tax Court’s recent decision in Anderson v. Commissioner, T.C. Memo. 2016-219. The decision highlights a potential foot fault they may make when trying to resolve their trust fund recovery penalties at the IRS administrative level. Facts and Procedural History The… Continue reading Judicial Review for Trust Fund Recovery Penalties
Innocent spouse relief can allow a taxpayer to avoid joint liability for taxes that arose during the marriage. If granted, the tax is generally computed as if each spouse filed their tax returns separately. If the couple is divorced at the time, there is an exception that can prevent the would-be innocent spouse from qualifying […]
The post Tax Court Expands Innocent Spouse Relief for Divorced Taxpayers appeared first on Houston Tax Attorney.
Innocent spouse relief can allow a taxpayer to avoid joint liability for taxes that arose during the marriage. There is an exception for the would-be innocent spouse if they had actual knowledge of the item that resulted in the tax. The U.S. Tax Court addressed this limitation in McDonald v. Commissioner, T.C. Summary Opinion 2016-79,… Continue reading Tax Court Expands Innocent Spouse Relief for Divorced Taxpayers
An IRS agent is generally required to get written approval from their manager for a tax penalty can be assessed. This is requirement is set out in the Code. This begs the question as to what happens if the agent does not get written approval before he closes the audit? The court addressed this in […]
The post Written Manager Approval for Penalties Not Required in Some Cases appeared first on Houston Tax Attorney.
