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Exxon’s Attempt to Create New Sale/Lease Tax Law Fails

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

IRS-Criminal Investigations Counts Down the Top 10 Cases of 2021

“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

Guidelines for Protecting Privilege in Tax Cases

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

ExxonMobil Discovers That Amended Tax Returns Are Dangerous

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

Tax Scam Alert: The Distraint Warrant

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

1/2/2020  /  IRS , Scams , Tax Fraud , Tax Liability , Tax Scams

Tax Cheats Can Go Wild In Dallas Texas

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

4/17/2015  /  IRS , Tax Evasion

IRS Telephone Fraud By “Mr. F-#-@-K Y-O-U”

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

2/17/2015  /  IRS , Tax Scams

Not Paying Your Employment Taxes? Prison Time Could Be In Your Future

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

IRS Computer Technology is Woefully Inadequate

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

2/5/2015  /  IRS , Technology

How to get the IRS to pay your legal fees

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

Want to get paid like Darryl Strawberry?

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

IRS Takes Money From Dead Mom to Pay For Son’s Tax Debt

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

7/31/2014  /  Beneficiaries , IRS , Tax Liens

Is the Internal Revenue Service Lying?

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

6/17/2014  /  Audits , Email , IRS , Tea Party

Do we really have a “Taxpayer Bill of Rights”?

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

Application For Tax Exempt Status To Be Eased By IRS – Except For The Tea Party

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

New Guidance From IRS On At-Risk Rules For LLC Member Guarantees

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

IRS Makes Bitcoins A Tax Headache

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

3/27/2014  /  Bitcoin , IRS , Property Tax , Virtual Currency

First Lady Of Tax Fraud

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

2/26/2014  /  Income Taxes , IRS , Tax Evasion , Tax Fraud

Gentleman’s Club Owner Hit With Fraud Penalty

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

Expansion Of IRS Innocent Spouse Relief

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

11/14/2013  /  IRS , Spousal Tax Relief

IRS Announces That All Legal Same-Sex Marriages Will Be Recognized For Federal Tax Purposes

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

Are You A Small Business? You Need To Take Advantage Of The Small Business Heath Care Credit

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

Top Reasons For Not Talking To An IRS Special Agent

The Fifth Amendment provides that “[n]o person…shall be compelled in any criminal case to be a witness against himself….”...more

“Breaking Bad” And Tax Evasion

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

6/21/2013  /  Audits , Back Taxes , IRS , Tax Evasion

Deadline To File FBARs Quickly Approaching

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

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