Author: Kreig Mitchell

Contribution of A Note to a Subsidiary: The Zero-Basis Rule

Businesses organized through multiple related entities routinely use promissory notes to move money between them. A parent company may issue a note to a subsidiary to capitalize it or fund operations. Affiliates lend to one another as part of ordinary treasury management. In the partnership context, a partner who wants to demonstrate additional financial commitment—but… Continue reading Contribution of A Note to a Subsidiary: The Zero-Basis Rule

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March 7, 2026
An Offer of IRS Appeals Review Can Preclude Judicial Review

The IRS assesses a tax penalty against you or your business. The audit closes and the IRS assesses the penalty. So how do you get a judge to look at it? For most tax disputes, the answer is the U.S. Tax Court. You can go there without first pre-paying the tax. But for certain types… Continue reading An Offer of IRS Appeals Review Can Preclude Judicial Review

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February 28, 2026
When the IRS Levies Estate Property, Whose Fight is it?

When a taxpayer dies with unresolved IRS issues—unpaid taxes, disputed levies, or unrefunded overpayments—the family often assumes that whoever inherits the estate can pick up where the decedent left off. That assumption might not be the correct. The tax code gives specific rights to specific parties. When the wrong person shows up in federal court… Continue reading When the IRS Levies Estate Property, Whose Fight is it?

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February 21, 2026
The IRS Audit Credit-Card-to-Cash Estimation Method for Cash Businesses

When it comes to income taxes, cash businesses have always been a challenge for the IRS. Cash is hard to track. Businesses, whether large or small, often fail to keep records of cash transactions. In other cases, businesses keep the records lose the records by the time the IRS audits the business years later. And… Continue reading The IRS Audit Credit-Card-to-Cash Estimation Method for Cash Businesses

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February 14, 2026
When Does a Tax Return Mistake Become a Crime?

The IRS has limited resources. This is true of its human capital and its technology resources. Even with significantly more resources, the IRS would still not be able to verify every entry on every return. There are just too many taxpayers, too many types of returns, and too many calculations and entries on the tax… Continue reading When Does a Tax Return Mistake Become a Crime?

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February 8, 2026
Estate Planning Attorney Personally Liable for Client’s Unpaid Taxes?

Estate planning and business attorneys often serve dual roles for their clients. Beyond providing legal advice, they might accept positions as registered agent, corporate secretary, or director of a client’s holding company. The arrangements can streamline matters and be a more efficient way to handle transactions. The attorney maintains control over corporate records, handles filings,… Continue reading Estate Planning Attorney Personally Liable for Client’s Unpaid Taxes?

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February 1, 2026
What “Authority” for Accountant Nullifies the Disability Exception for Tax Refunds?

Deadlines are a central feature of our tax system. We have written about many of these various deadlines on this website. From deadlines for filing returns, deadlines for various tax elections, to deadlines for filing appeals from audits, to deadlines for filing collection actions, deadlines for appeling IRS audits, and even tax court and other… Continue reading What “Authority” for Accountant Nullifies the Disability Exception for Tax Refunds?

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January 24, 2026
Can an Active Limited Partner Avoid Self-Employment Tax?

Self-emploiyment taxes are an additional tax over and above any income tax that may be due. The amount can be significant—these Social Security and Medicare taxes can add up to 15.3% on top of ordinary income tax rates. For smaller businesses, it is often a very large part of the overall tax due. How this… Continue reading Can an Active Limited Partner Avoid Self-Employment Tax?

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January 17, 2026
When Providing Information to the IRS Discloses Additional Tax Due

The IRS consumes information about taxpayers. By and large, that is what the IRS is–a vacuum for information. It then processes the information and applies statutorily mandated processes to evaluate the information. The processes are geared toward evaluating whether additional tax is owed and then recording that balance on the IRS’s books, so that the… Continue reading When Providing Information to the IRS Discloses Additional Tax Due

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January 10, 2026