Imagine that you earned significant income and failed to file tax returns. You later file the tax returns once the IRS caught on to you, but you omitted a large part of your income. The government indicts you on criminal tax evasion charges, and starts an IRS audit. Before the criminal trial, the IRS audit……
Tag: Tax Procedure
How Wrong Does the IRS Have to be to Be Liable for Attorneys Fees?
In most civil litigation cases, the parties are not entitled to an award of attorneys fees. The exceptions are generally when there is a contract that provides for attorneys fees or there is a statute. This can be problematic in litigation cases–particularly where one party brings or defends a friviolous suit just to drive up……
Is a Taxpayer Accountable for their Tax Preparer’s Fraud?
Most taxpayers opt to hire professionals to prepare their tax returns. Tax professionals understand the complexities of deductions, credits, and reporting requirements that can overwhelm even sophisticated business owners and investors. Once the tax returns are filed and a few years pass without incident, most taxpayers reasonably assume those tax years are closed forever. But……
Can the IRS Disclosure Your Tax Info in Cases Agains Other Taxpayers?
You cooperate with an IRS audit. You provide detailed financial records. You answer questions about your business. Years later, you discover the IRS is using your information in cases against other taxpayers. The IRS is sharing details about your business location, your EIN, even the fact you’re under investigation for a tax promoter penalty. Is……
Does DOJ Referral Strip IRS of Power to Process Refund Claim?
You think the IRS owes you a refund. You file a refund claim. The IRS eventually processes your refund, but does not issue checks to refund the money to you. You later find out that the IRS had referred the matter to the Department of Justice–maybe you find out years later even. Can the simple……
When Can the IRS Levy Church Assets as “Nominee” Property?
Religious organizations and churches often own property and bank accounts that support their mission and operations. Sometimes, these assets are also used to benefit the organization’s leaders personally. This begs the question, can the IRS collect on the religious organization or church’s assets for the individuals tax debt? Can the IRS use the “nominee” rules……
Court Limits Equitable Tolling For Late Tax Court Petitions
We live in a fast-paced world where technology has made it possible to do more, see more, and accomplish everything else more efficiently. While some routines of life have not changed, most have been transformed by our increasingly connected environment. For better or worse, one thing that has not changed is the concept of deadlines,……
Tax Court Strikes IRS Timeline for Partnership Adjustments
The partnership audit regime rules are not all that new at this point. But what makes them new is that the IRS hasn’t fully implemented them, is often not following the new rules, and the disputes involving this have just started to trickle up to the courts. Practitioners are also at fault here. Many have……
No AutomaticDenial for ERC Claims Below 10% Threshold
The IRS has called out improper Employee Retention Credit claims filed by taxpayers and their advisors. It has also failed to pay many valid claims, even to this very day. The IRS has taken a position that ERC claims based on partial shutdown due to government orders require a 10 percent reduction in gross receipts……