The U.S. Supreme Court has made it clear that taxpayers cannot avoid penalties by blindly rely on tax advisors to file tax returns and make tax payments. These situations are unfortunate. The court in Specht v. United States, No. 15-3095 (6th Cir. 2016) highlights one way that taxpayers may be able to avoid the bright […]
The post Court Revisits Reasonable Cause for Abating Penalties appeared first on Houston Tax Attorney: Texas Lawyer.
The U.S. Supreme Court has made it clear that taxpayers cannot avoid penalties by blindly rely on tax attorneys to file tax returns and make tax payments. These situations are unfortunate. The court in Specht v. United States, No. 15-3095 (6th Cir. 2016) highlights one way that taxpayers may be able to avoid the bright… Continue reading Court Revisits Reasonable Cause Abating Penalties
There are a number of cases where taxpayers have had to pay more tax than they should due to technical foot faults. These cases often come up when the IRS auditors believe that their job is to look for strict compliance (100%) rather than substantial compliance (something more akin to 80%). This brings us to… Continue reading Charitable Deduction With a Defective Valuation
Taxes Remitted to the U.S. Virgin Islands in Error were Not Compulsory Payments in an Audit One of the common issues that comes up on audit is whether payments to foreign governments are creditable for purposes of the U.S. foreign tax credit (“FTC”). This often hinges on whether the payments were “compulsory.” There is little… Continue reading Taxes from IRS Audit Remitted to U.S. Virgin Islands
The IRS puts taxpayers on notice by mailing letters and notices. It is common for these letters and notices to not be delivered or to be delivered late. This can present a serious problem for taxpayers, particularly when the letter or notice is one tha…
The IRS puts taxpayers on notice by mailing letters and notices. It is common for these letters and notices to not be delivered or to be delivered late. This can present a serious problem for taxpayers, particularly when the letter or notice is one that proposes to increase the about of tax that is due.… Continue reading Options to Contest Taxes
Agreeing to Extend the Time for an IRS Audit or Not? Congress provided a limited time for the IRS to audit tax returns. This time can be extended if the taxpayer agrees. While some taxpayers require the IRS to stick to the time provided by Congress, other taxpayers choose to extend the time period. This… Continue reading Extend Time for an IRS Audit
The Tax Code imposes several artificial deadlines and consequences for not meeting those deadlines. Many tax deadlines are strict. The result in tax cases often come down to whether a taxpayer can prove that he met these deadlines. In Chan v. United States, No. 2:15-cv-739-DN-BCW (D. Utah 2016), the court considered whether an Adobe PDF… Continue reading How to Prove Refund Claim Timely Filed
We often get questions as to whether IRS agents can contact various third parties during the course of an IRS audit. The general rule is that IRS agents can in fact contact third parties. And they sometimes do. The ability to do this is limited and it does not exempt IRS agents from the confidentiality… Continue reading IRS Agents Contact Third Parties During IRS Audit
There are a number of forums for litigating tax disputes, such as the U.S. Tax Court. There are pros and cons associated with bringing suit in each forum. Taxpayers often pass on litigating cases in the U.S. Tax Court in cases when they are seeking a r…
