TIGTA Review of the IRS’s Practices in Levying on Social Security Payments

Real Estate Professionals Subject To Material Participation Rules

The IRS has the power to levy on or take a taxpayer’s property. This includes nearly all property, including Social Security payments. The Treasury Inspector General for Tax Administration (TIGTA), the agency that audits the IRS, recently released a report that examined the IRS’s practices in levying on Social Security payments. Social Security Payments TIGTA’s… Continue reading TIGTA Review of the IRS’s Practices in Levying on Social Security Payments

The IRS’s Streamlined Procedures for Foreign Accounts

Online Account Trigger Fbar Filing, Not Poker Websites

Given its limited resources and ability to detect foreign assets, accounts and income, the IRS has offered various voluntary programs to entice taxpayers to come clean and report this information. The IRS’s OVDP program and the more recent streamlined procedures are two examples. The Maze v. Internal Revenue Service, Nos. 15-1806 (D.D.C. 2016), highlights several… Continue reading The IRS’s Streamlined Procedures for Foreign Accounts

Online Account Trigger FBAR Filing, Not Poker Websites

Online Account Trigger Fbar Filing, Not Poker Websites

In Hom v. United States, No. 14-16214 (9th Cir. 2016), the court addressed whether an online payment account and whether poker websites triggered FBAR filing requirements. The stakes are high with FBAR penalties, so those with foreign accounts should take heed. FBAR Filing Requirements Taxpayers with an interest in or authority over certain foreign accounts… Continue reading Online Account Trigger FBAR Filing, Not Poker Websites

Court Says Five IRS Audits in Ten Years is Not Harassment

In Appenrodt v. United States, No. 3:16-cv-02010-LB (N.D. Cal. 2016), the court concluded that the IRS did not harass a taxpayer by subjecting the taxpayer to five audits in ten years. The facts and procedural history of the case are as follows: The IRS audited Mr. Appenrodt’s individual income tax returns for tax years 2005-2008.[…]

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Five IRS Audits in Ten Years is Not Harassment

Five Irs Audits In Ten Years Is Not Harassment

There are times when the IRS does not act reasonably. It happens. There are also instances where a few IRS employees take it upon themselves to thoroughly examine all aspects of the taxpayer’s finances. Taxpayers do have rights, but these rights only go so far. This brings us to the Appenrodt v. United States, No.… Continue reading Five IRS Audits in Ten Years is Not Harassment

IRS Whistleblower Claimants May Be Entitled to Larger Awards

Irs Audit Adjustments That Change Accounting Methods

The IRS is often gets more from whistleblowers than one may think. Specifically, the IRS may be able to recoup taxes, penalties and interest for other years or related but different issues. There is a question as to whether the whistleblowers who shine the light on these other years or issues should be compensated for… Continue reading IRS Whistleblower Claimants May Be Entitled to Larger Awards