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… Continue reading Reportable Transaction Penalty, Full Payment Required
Tax Articles
Can IRS Cure Defective Summons With Second Summons?
The administrative summons is one of the IRS’s primary tools for obtaining information from taxpayers and third parties. There are very few requirements that the IRS has to satisfy in issuing summones. In Maxcrest Limited v. United States, Case No. 15-mc-80270-JST, the U.S. District Court for the Northern District of California addressed whether the IRS […]
The post Can IRS Cure Defective Summons With Second Summons? appeared first on Houston Tax Attorney.
Can IRS Cure Defective Summons With Second Summons?
The administrative summons is one of the IRS’s primary tools for obtaining information from taxpayers and third parties. There are very few requirements that the IRS has to satisfy in issuing summones. In Maxcrest Limited v. United States, Case No. 15-mc-80270-JST, the U.S. District Court for the Northern District of California addressed whether the IRS… Continue reading Can IRS Cure Defective Summons With Second Summons?
Lost IRS Notice Was Timely, Despite IRS Not Following Procedures
There are a number of dates that must be met when it comes to taxes. Many of these dates are triggered by some action by the IRS. This raises the question as to what happens if the taxpayer is not aware that the IRS took the action and the IRS destroys the primary evidence that […]
The post Lost IRS Notice Was Timely, Despite IRS Not Following Procedures appeared first on Houston Tax Attorney.
Lost IRS Notice Was Timely, Despite IRS Not Following Procedures
There are a number of dates that must be met when it comes to taxes. Many of these dates are triggered by some action by the IRS. This raises the question as to what happens if the taxpayer is not aware that the IRS took the action and the IRS destroys the primary evidence that… Continue reading Lost IRS Notice Was Timely, Despite IRS Not Following Procedures
TIGTA Suggests IRS Follow Transfer Pricing Roadmap
Transfer pricing is and has been the most significant and difficult issue the IRS audits. The audits are typically closed with the IRS agents proposing unreasonably large adjustments and IRS appeals sustaining a very low percentage of the adjustments. The IRS has not been very successful in litigating transfer pricing cases either. As a result, […]
The post TIGTA Suggests IRS Follow Transfer Pricing Roadmap appeared first on Houston Tax Attorney: Texas Lawyer.
TIGTA Suggests IRS Follow Transfer Pricing Roadmap
Transfer pricing is and has been the most significant and difficult issue the IRS audits. The audits are typically closed with the IRS agents proposing unreasonably large adjustments and IRS appeals sustaining a very low percentage of the adjustments. The IRS has not been very successful in litigating transfer pricing cases either. As a result,… Continue reading TIGTA Suggests IRS Follow Transfer Pricing Roadmap
Stay-at-Home Mom Not Liable for Trust Fund Recovery Penalty
The IRS has the ability to assess a trust fund recovery penalty against those who are responsible for withholding payroll taxes for employees if they fail to withhold and pay over the taxes to the IRS. Then penalty is equal to the amount of the withheld but unpaid tax. Liability for the penalty falls on […]
The post Stay-at-Home Mom Not Liable for Trust Fund Recovery Penalty appeared first on Houston Tax Attorney: Texas Lawyer.
Stay-at-Home Mom Not Liable for Trust Fund Recovery Penalty
The IRS has the ability to assess a trust fund recovery penalty against those who are responsible for withholding payroll taxes for employees if they fail to withhold and pay over the taxes to the IRS. Then penalty is equal to the amount of the withheld but unpaid tax. Liability for the penalty falls on… Continue reading Stay-at-Home Mom Not Liable for Trust Fund Recovery Penalty
Ability to Change Roof Disqualifies Facade Easement Deduction
In Partita Partners, LLC. v. United States, No. 15-cv-2561 (S.D.N.Y. 2016), the court considered whether the taxpayer was entitled to a charitable deduction for donating a facade easement to charity. The issue was whether the retaining the right to change the roof on the building negated the charitable deduction for donating the facade easement. About […]
The post Ability to Change Roof Disqualifies Facade Easement Deduction appeared first on Houston Tax Attorney: Texas Lawyer.