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Audits Income Taxes Internal Revenue Service

Allen Barron, Inc.

What to do if You Receive an IRS Audit Notification Letter 0724

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What should you do if you receive an IRS audit notification letter? Why should you consider engaging an experienced IRS audit and tax attorney who represents U.S. taxpayers facing an IRS audit or any other federal or state...more

Foodman CPAs & Advisors

Correo Del IRS

En su mayor parte, los contribuyentes no quieren recibir correo del IRS ni abrir correo del IRS. Es por eso por lo que el IRS emitió el Consejo Fiscal (“Tax Tip”) 2024-45 el 6 de mayo de 2024 para informar a los...more

Foodman CPAs & Advisors

Mail From The IRS

For the most part, Taxpayers do not want to receive mail from the IRS or open mail from the IRS. This is why IRS issued Tax Tip 2024-45 on May 6, 2024 to let taxpayers know what taxpayers should do if they receive mail from...more

Rivkin Radler LLP

Collecting an Individual’s Unpaid Taxes from Their Controlled Entities

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An anonymous thinker, lost to history, is credited with having said that the unofficial motto of the IRS is, “We have what it takes to take what you have.” In some instances, the truth of the above statement is manifested in...more

Allen Barron, Inc.

When to Consider the IRS Voluntary Disclosure Program or VDP

Allen Barron, Inc. on

Are you wondering when a US taxpayer should consider the IRS Voluntary Disclosure Program or VDP? Are you concerned about unreported or under-reported income, financial accounts, assets, investments, cryptocurrency or...more

Rivkin Radler LLP

Missing the Tax Court’s 90-Day Deficiency Deadline – Now What?

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Over the years, I have observed there is only one thing that a taxpayer fears more than being notified by the IRS that their income tax return for a particular taxable year has been selected for audit, and that is being...more

Foodman CPAs & Advisors

¿Es Un Hobby O Negocio?

Los contribuyentes pueden enfrentarse a la pregunta: “¿Es un hobby o negocio?”. El IRS afirma que: “a veces la línea entre tener un hobby y administrar un negocio puede ser confusa, pero conocer la diferencia es importante...more

Foodman CPAs & Advisors

Is It A Hobby Or Business?

Taxpayers may be faced with the question: “Is it a hobby or business?” The IRS states that: “sometimes the line between having a hobby and running a business can be confusing, but knowing the difference is important because...more

Seward & Kissel LLP

Crypto Tax Evasion is Just…Tax Evasion

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Tax evasion is as old as tax collection, so it is no surprise that there is tax evasion related to crypto. In a recent case, United States v. Frank Ahlgren III, Federal prosecutors allege that between 2017 and 2019, the...more

Eversheds Sutherland (US) LLP

IRS sees flight risk with corporate jets

On February 21, 2024, the IRS announced a new initiative to audit large corporate taxpayer use of corporate jets, as part of a larger initiative focused on tax compliance of large corporations and high-income taxpayers. The...more

Allen Barron, Inc.

IRS Focuses Scrutiny on High-Income Taxpayers, Partnerships and Corporations

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New issues come into focus as the IRS focuses scrutiny on high-income taxpayers, partnerships and corporations, as well as those who promote the abuse of tax rules.  The IRS has formally given notice that it intends to...more

Woods Rogers

IRS Announces New Initiatives to Restore Fairness to Tax System

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On September 8, 2023, the IRS announced the start of a “sweeping, historic effort to restore fairness in tax compliance by shifting more attention onto high-income earners, partnerships, large corporations and promotors...more

Foley & Lardner LLP

Cos. Should Heed IRS Warnings About Employee Tax Credit

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For most businesses, turning the calendar to 2023 meant putting the pandemic and any of its tax-related effects further in the rearview mirror. One notable exception, however, is the employee retention credit, or ERC,...more

Rivkin Radler LLP

New York Examines Federal Income Tax Issues –Conformity and . . . Disclosure?

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Many years ago, New York revised its personal income tax law to achieve close conformity with the Federal system of income taxation. The stated purpose for the revision was to simplify tax return preparation, improve...more

Venable LLP

Taxpayers and Tax Preparers, Beware of Automated Notices of Deficiency

Venable LLP on

The IRS has increased its practice to issue Notices of Deficiency without an audit. For example, if there is a mismatch between what was reported on a Form 1099 for a taxpayer and the income shown on the taxpayer's return, or...more

Foodman CPAs & Advisors

Lista De Verificación De Preguntas Sobre Activos Digitales Del Formulario 1040 Del 2022

El Formulario 1040 2022 cambia la terminología criptográfica de “moneda virtual” a “activos digitales”. El propósito del cambio en la terminología podría interpretarse como un “aviso” a los contribuyentes de que el IRS está...more

McDermott Will & Emery

IRS to Update Schedule UTP to Require Additional Transparency

McDermott Will & Emery on

On October 11, 2022, the Internal Revenue Service (IRS) announced draft changes to Schedule UTP, Uncertain Tax Position Return Statement, and Form 1120, Instructions for Schedule UTP, for the 2022 tax year (processing year...more

Holland & Knight LLP

Willful or Non-Willful? That Is the Question: IRS Rejects Non-Willful Certification

Holland & Knight LLP on

In Flint v. United States, 2022 WL 3593826 (Fed. Cl. 2022), the court held that the executors of an estate could not recover a six-figure "Title 26 miscellaneous offshore penalty" (MOP) the decedent paid to the Internal...more

Rivkin Radler LLP

Reasonable Compensation Meets The Principal Shareholder of a C Corp

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Double Tax- The shareholders of C corporations have long sought legitimate operational and transactional structures by which they may reduce the double tax hit that is realized when such a corporation distributes its...more

White and Williams LLP

2022 Tax Filing Season: Nine Things You Need to Know

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The 2022 tax season is upon us. With what promises to be an unusual tax filing season, below are nine updates and tips to keep in mind. 1. Tax Returns are Lagging. On January 12, the National Taxpayer Advocate issued its...more

McDermott Will & Emery

Extending the Statute of Limitations for Assessing Federal Tax

McDermott Will & Emery on

We previously provided an overview of the time limits imposed on the Internal Revenue Service (IRS) for assessing federal tax. The general rule is that the IRS must assess tax within three years from the later of the due date...more

Rivkin Radler LLP

“Opaque Income Sources” + “Tax Gap” = More Enforcement + Tax Hikes = Anyone’s Guess

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Tax Gap- In a report released last week, the U.S. Treasury Department explained that the so-called “tax gap” – i.e., the difference between the amount of federal income taxes owed by taxpayers for a taxable year and the...more

Downs Rachlin Martin PLLC

AFP: $80 Billion to Audit Businesses and Wealthy in Biden Plan

On April 28, 2021, President Biden presented the “American Families Plan” (AFP), an ambitious spending program focused on providing family leave, child care and nutrition, health care, preschool and college education to...more

Holland & Knight LLP

IRS Continues to Audit and Litigate Against Cannabis Businesses

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As Congress continues to deliberate the federal legalization of marijuana, the cannabis industry continues to face scrutiny from the IRS under Section 280E of the Internal Revenue Code (Code). Enacted in 1982 in response to a...more

Freeman Law

IRS Publishes Proposed BBA Regulations on Special Enforcement Matters

Freeman Law on

Over 5 years ago, then President Obama ushered in sweeping changes to the method and manner in which partnerships are audited and partnership tax is assessed and collected through his signing of H.R. 1314, the Bipartisan...more

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