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… Continue reading Written Manager Approval for Penalties
Tax Articles
IRS Closing Agreement Not Binding for “All” Tax Issues
A well drafted closing agreement can provide a level of certainty to an uncertain tax position. The agreements do this by binding the IRS and the taxpayer. They normally include language that says that the agreements are valid for all Federal income tax purposes. In Analog Devices, Inc. v. Commissioner, 147 T.C. 15, the court […]
The post IRS Closing Agreement Not Binding for “All” Tax Issues appeared first on Houston Tax Attorney.
IRS Closing Agreement Not Binding for “All” Tax Issues
A well-drafted closing agreement can provide a level of certainty to an uncertain tax position. The agreements do this by binding the IRS and the taxpayer. They normally include language that says that the agreements are valid for all Federal income tax purposes. In Analog Devices, Inc. v. Commissioner, 147 T.C. 15, the court concluded… Continue reading IRS Closing Agreement Not Binding for “All” Tax Issues
Court Invalidates Longstanding Process to Challenge IRS Levy
If the IRS fails to mail or mails a notice to a taxpayer and uses the wrong address, should the taxpayer be faulted for missing the deadline set out in the IRS notice? The Seventh Circuit Court of Appeals says “yes” in Adolphson v. Commissioner, No. 15-2242. The facts and procedural history are as follows: […]
The post Court Invalidates Longstanding Process to Challenge IRS Levy appeared first on Houston Tax Attorney.
Court Invalidates Process to Challenge IRS Levy
If the IRS fails to mail a collection notice to the taxpayer or if it mails a required collection notice to a taxpayer using the wrong address, should the taxpayer be able to get a court ruling invalidating the IRS’s subsequent collection efforts? Congress added several notice requirements to help protect taxpayers from unlawful IRS… Continue reading Court Invalidates Process to Challenge IRS Levy
Court Considers Whether Moneygram is a Bank that Makes Loans
There are tax laws that provide significant tax advantages to banks. One of these laws allows banks to deduct capital losses against ordinary income. This allows banks to deduct losses immediately when others might have to carryover the loss to other tax years. There are other tax laws that are specific to banks. These laws […]
The post Court Considers Whether Moneygram is a Bank that Makes Loans appeared first on Houston Tax Attorney.
Court Considers Whether Moneygram is a Bank that Makes Loans
There are tax laws that provide significant tax advantages to banks. One of these laws allows banks to deduct capital losses against ordinary income. This allows banks to deduct losses immediately when others might have to carryover the loss to other tax years. There are other tax laws that are specific to banks. These laws… Continue reading Court Considers Whether Moneygram is a Bank that Makes Loans
IRS Wage and Salary Levy Exemptions for 2017
The IRS recently issued Publication 1494, Tables for Figuring Amount Exempt From Levy on Wages, Salary, and Other Income – Forms 668-W(ACS), 668-W(c)(DO) and 668-W(ICS), for 2017. This publication provides the amount of wage and salary that are exempt from the IRS’s levy. The monthly wage and salary amounts for 2017 are as follows: Exemptions […]
The post IRS Wage and Salary Levy Exemptions for 2017 appeared first on Houston Tax Attorney.
Reportable Transaction Penalty Not Divisible, Full Payment Required to Bring Suit
Tax matters can be litigated in a number of different courts. One of the advantages of bringing suit in U.S. Tax Court is that the tax does not have to be paid prior to bringing suit. For tax matters litigated in the U.S. District Courts or the Court of Federal Claims, the tax has to […]
The post Reportable Transaction Penalty Not Divisible, Full Payment Required to Bring Suit appeared first on Houston Tax Attorney.
IRS Wage and Salary Levy Exemptions for 2017
The IRS recently issued Publication 1494, Tables for Figuring Amount Exempt From Levy on Wages, Salary, and Other Income – Forms 668-W(ACS), 668-W(c)(DO) and 668-W(ICS), for 2017. This publication provides the amount of wage and salary that are exempt from the IRS’s levy. The monthly wage and salary amounts for 2017 are as follows: Exemptions… Continue reading IRS Wage and Salary Levy Exemptions for 2017