The principal contention in the tax refund case of Exxon v. United States was whether certain mineral related transactions between Exxon and the countries of Qatar and Malaysia were sales or leases. Originally Exxon treated...more
11/9/2022
/ Corporate Taxes ,
Exxon Mobil ,
Gas Royalties ,
Income Taxes ,
IRS ,
Lease Tax ,
Malaysia ,
Mineral Leases ,
Oil & Gas ,
Profits ,
Qatar ,
Revenue ,
Sales Tax ,
Statements of Economic Interest ,
Tax Liability ,
Tax Refunds
“The investigative work of 2021 has all the makings of a made for TV movie – embezzlement of funds from a nonprofit, a family fraud ring that stole millions in COVID-relief funds and a $1 billion Ponzi scheme used to buy...more
1/10/2022
/ Bank Fraud ,
Bitcoin ,
Criminal Conspiracy ,
Criminal Investigations ,
Criminal Prosecution ,
Embezzlement ,
Enforcement Actions ,
Income Taxes ,
Investment Fraud ,
IRS ,
Mail Fraud ,
Money Laundering ,
Payday Loans ,
Ponzi Scheme ,
Scams ,
Tax Evasion ,
Tax Fraud ,
Tax Returns ,
Wire Fraud
Lawyers, tax or otherwise, understand that privileged information must be protected to encourage a full and frank dialogue that might not occur without confidentiality.1 Tax information, in particular, contains some of the...more
In Exxon Mobil Corp. v. United States of America, from the United States District Court for the Northern District of Texas, ExxonMobil learned the hard way that filing amended tax returns can be very costly....more
2/3/2021
/ Amended Tax Returns ,
Corporate Counsel ,
Exxon Mobil ,
IRS ,
Malaysia ,
Mineral Leases ,
Oil & Gas ,
Partnerships ,
Qatar ,
Tax Fraud ,
Tax Liability ,
Tax Refunds ,
Tax Returns
Last week, we received a letter that purported to be from the “Tax Processing Unit – Tarrant County Public Judgment Records.” The letter surprised us because it was in a form that we had not previously encountered and we...more
The Washington Post published an article on April 8, 2015 titled “In Dallas, the IRS says it can’t chase tax cheats who owe less than $1 million.” Here is a section of the article...more
Every year the IRS sends out its “Dirty Dozen” list. This is a compilation of the most prevalent tax scams, with the intent to inform and warn taxpayers of tax related rip-offs.
The very first on the list involves...more
It is a very common story for small businesses to get behind on paying employment taxes. Federal employment taxes are largely made up of FICA and withholding taxes. The IRS is especially keen on businesses who fail to pay...more
CNN recently released a fascinating look at the computers the IRS uses in “IRS Says It’s Using Technology From JFK’s Time.” IRS Commissioner John Koskinen states that the IRS computer system is “like driving a Model T that...more
What can you do when the IRS is misbehaving and it directly affects you?
You will have to fight them, but the law allows you to recover your litigation costs if you win.
As many know, the IRS has had a very...more
The IRS is auctioning off a deferred compensation arrangement Darryl Strawberry had with the Mets. Minimum bid is $550,000 for a payment stream that is estimated to be well over $1 million. Get your bid in by January 20th...more
Most people have some strong feelings about how they want their assets to be distributed upon their death. Some want to give their money to their kids, others are charitably inclined. However, I would guess that very few...more
Do you remember the controversy where the IRS was accused of targeting and unfairly auditing the Tea Party?
In an article Sunday from CNN’s Political Ticker by Sara Fischer, the IRS has claimed that it is unable to...more
The IRS announced the adoption of a “Taxpayer Bill of Rights” Tuesday. I have listed the rights below along with my commentary. Just like our U.S. Constitutional Rights, these “rights” are and will be watered down....more
In 2013, the IRS revealed that it had selected ”social welfare” groups (like the Tea Party) applying for tax-exempt status for closer scrutiny. That investigation is still ongoing and it has given the IRS a black eye....more
The IRS recently released a chief counsel memorandum AM2014-003 on LLC Member Guarantees of LLC Debt and “Qualified Nonrecourse Financing.” These memorandums are very helpful because they provide the IRS’ interpretation of...more
The IRS just published Notice 2014-21 which explains the IRS’ vision on how general tax principals apply to “virtual currency” transactions like Bitcoin....more
The IRS just issued its Criminal Investigation Annual Report. Budget constraints caused the staffing of Special Agents to drop to the lowest numbers in recent history, but 2013 included a 12.5 percent increase in...more
A new Tax Court decision just came out – Potter v. Commissioner, TC Memo 2014-18. The case involved a “gentleman’s club” owner in Michigan.
In December 2006 IRS special agents engaged in an undercover investigation of...more
On September 13th the IRS issued a new revenue procedure that significantly changes equitable innocent spouse relief.
I have excerpted part of the article which discusses the significant changes.
Originally...more
The IRS issued a press release today that is significant for same sex spouses. The changes are discussed more fully in Rev. Proc. 2013-17 and generally reflect the holding in the Supreme Court’s decision in U.S. v....more
Whether Obamacare is good or not remains to be seen. To lessen the pain for small employers, the IRS does provide for a small business health care credit. If you are a small business you should take advantage. ...more
The Fifth Amendment provides that “[n]o person…shall be compelled in any criminal case to be a witness against himself….”...more
I love the TV Series “Breaking Bad” on AMC. In a nutshell, it is about a tough luck high school chemistry teacher named Walter White who turns into a major drug dealer and murderer. ...more
There is absolutely nothing wrong with having a foreign bank account. The problem comes along when the existence of the account is not disclosed and income associated with the account is not reported....more