There are those who make things happen. They are usually the ones doing what it takes even when doing so is difficult, tiring, and draining. They are the ones that often make personal sacrifices and take risks to succeed. They are the ones that had the luck or grit to stick with something to see… Continue reading Double Tax on Inter-Company Transfers
Category: IRS Audits
About IRS Audits
The IRS uses the audit process to increase the amount of tax you owe. It is an adversarial process and should be handled accordingly.
This page covers recent cases, rulings, and guidance for IRS audits. Scroll down to read the articles.
If you want to read more about IRS audits or see how we can help, you can read this page about IRS audits.
Otherwise, if you need help dealing with an IRS audit, please schedule an appointment with our tax attorneys online. You can also call us at (713) 909-4906.
IRS Documentation for Travel Expenses
Business travel expenses are deductible. These are expenses for business trips and work trips, such as car and truck expenses, airfare and hotels and lodging. It can also include travel meals. Those looking to deduct business trip expenses are running a risk as the IRS frequently disallows these expenses on audit. It does so even… Continue reading IRS Documentation for Travel Expenses
Adequate Dislcosure to Avoid Six Year IRS Statute
The IRS has a limited period of time to conduct audits. It often fails to finish the audit within this period of time. There are even instances where the IRS does not even start the audit until after this time period has passed. This raises tough questions for taxpayers. Taxpayers expect some finality with their… Continue reading Adequate Dislcosure to Avoid Six Year IRS Statute
What is a Repetitive IRS Audit?
When it comes to the IRS and audits, there are times when a taxpayer may feel like they can’t win. This is often true. If you have been reading this site for some time, you may recall our article involving Five Audits in Ten Years and the court concluding that this many audits in such… Continue reading What is a Repetitive IRS Audit?
Getting the IRS to Act Timely
There are quite a few avenues available to resolve tax disputes with the IRS. We have previously considered these options for resolving tax cases in a prior article. The number of avenues available can make it difficult to navigate the IRS bureaucracy. This plus the slow pace at which the IRS works makes it very… Continue reading Getting the IRS to Act Timely
Can the IRS Waive Compliance With Tax Rules?
What happens if you make a technical foot fault while working with the IRS? Say you miss a deadline or a filing requirement. Can the IRS waive compliance with the deadline or requirement? IRS personnel will often say that they cannot. But in reality, the IRS can waive most procedural requirements. The authority for this… Continue reading Can the IRS Waive Compliance With Tax Rules?
Does an IRS Audit Waive a Defect in Tax Return?
When it comes to technicalities in the tax law, the failure to comply with some technicalities can be overcome. Others cannot. As a general rule, the courts evaluate tax disputes involving technicalities based on the policy underlying the technicality versus fairness for requiring strict compliance. If the policy for the technicality is important, the court… Continue reading Does an IRS Audit Waive a Defect in Tax Return?
Electing Out of the Partnership Audit Regime
When it comes to income taxes and IRS audits, there are a lot of procedural rules that are counter-intuitive. Even if one thinks they are half-baked, the rules are the rules. They can have serious consequences. The centralized partnership audit regime is an example. Tax advisors often instruct their clients to elect out of the… Continue reading Electing Out of the Partnership Audit Regime
Can You Rely on IRS Statements?
If you ask someone a direct question and the person responds with incorrect information, is the person bound by their misrepresentation? This raises questions of “estoppel,” which apply to most litigants. But does it apply to IRS employees who make a misrepresentation? Put another way, can you rely on statements by IRS representatives? The court… Continue reading Can You Rely on IRS Statements?
When an IRS Agent Makes a Misrepresentation
IRS agents interact with taxpayers. In doing so, they make misrepresentations as any other human does. Some are unintentional and some are intentional. But what is a taxpayer to do if the IRS agent makes a misstatement and it negatively impacts the taxpayer? The McRae v. Commissioner, T.C. Memo. 2019-163, case touches on this issue.… Continue reading When an IRS Agent Makes a Misrepresentation