Missing Form 1099 May Establish Reasonable Cause

Missing Form 1099 May Establish Reasonable Cause

If you do not receive a Form 1099 to report income to you and you omit it from your tax return, are you liable for penalties if the IRS later notices the issue and makes an adjustment?  The Mabinuori v. Commissioner, T.C. Summary Opinion 2006-109, case provides an opportunity to consider this question. Facts & Procedural… Continue reading Missing Form 1099 May Establish Reasonable Cause

Abatement of Tax Penalties and Interest

Abatement Of Tax Penalties And Interest

Many unfortunate taxpayers find themselves in the position of owing a tax debt that consists of a small tax liability and a large assessment of tax penalties and interest. In many of these cases the penalties and interest can be substantially larger than the original tax debt. This situation often forces taxpayers to seek the… Continue reading Abatement of Tax Penalties and Interest

Drug Addiction Excuse for Filing Tax Return Late?

Drug Addiction Excuse For Filing Tax Return Late?

Can drug addiction or migraines be an excuse for filing a tax return late? The court addresses this in Jordan v. Commissioner, T.C. Memo. 2005-266, for a life insurance salesman who became addicted to OxyContin prescribed for his severe headaches. Facts & Procedural History Mr. Jordan was a life insurance salesman. Mr. Jordan had a… Continue reading Drug Addiction Excuse for Filing Tax Return Late?

Better than a Soap Opera? Trust Fund Tax Disputes

Better Than A Soap Opera? Trust Fund Tax Disputes

Businesses often succumb to the temptation to use taxes withheld from employees wages to manage cash flow problems. These “government loans” can prove to be quite costly. Hart v. Commissioner, 19120-12 provides an example. Facts & Procedural History The taxpayer worked for a real estate firm. The firm did not pay its payroll taxes. The… Continue reading Better than a Soap Opera? Trust Fund Tax Disputes

Tax Liability Review by Tax Court Limited

The collection due process hearing law has provided taxpayers with another avenue for challenging their underlying tax liabilities. With this option, taxpayers can let the IRS assess the additional tax or penalties and then wait for the IRS to attempt enforced collection for the balance. They can then file a collection due process hearing request… Continue reading Tax Liability Review by Tax Court Limited