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……
Tag: Tax Procedure
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……
Settling Tax Debts Based on “Future Income” for Business Owners
The IRS settles balances for back taxes for less than what is owed through the “offer in compromise” program. The idea of this program is to allow taxpayers to have a so-called “fresh start” when they get really behind. This way the IRS collects something rather than nothing. Those who work as employees are less……
Sidestep Tax Court Review by Applying Overpayments
What happens when a taxpayer properly invokes their right to challenge the underlying tax liability through the CDP process, but the IRS then uses subsequent overpayments to zero out the disputed balance? Can the IRS effectively eliminate tax court jurisdiction by manipulating these overpayments mid-process, leaving the taxpayer without any forum to resolve their legitimate……
IRS Collections: Can Taxpayers Rely on IRS Statements?
Taxpayers who enter into payment arrangements with the IRS often believe they are safe from IRS collection actions. Many assume that agreeing to monthly payments will prevent the government from filing tax liens. This assumption seems reasonable given the IRS’s own published guidelines. These guidelines suggest liens won’t be filed in certain circumstances. But can……
When the IRS Agrees You’re Right But the Court Says You’re Wrong
Say the IRS agrees that you are entitled to a sizeable tax deduction. But on audit, the IRS determines that you reported the tax deduction using the wrong form. The form used does not change the amount of the tax deduction or the taxpayer that would ultimately pay the tax. From the IRS’s perspective, the……
Can Limited Partners be Subject to Self-Employment Tax?
Investment funds are often structured as limited partnerships. These partnerships allow professional managers to pool investor funds while maintaining operational flexibility. These structures typically have a general partner (“GP”) who manages day-to-day operations. Limited partners (“LP”) provide the capital and earn passive returns. The active manager and passive investor roles have different tax implications. Self-employment……