News & Analysis as of October 12, 2024

Tax Debt

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

IRS Cannot Offset Taxpayer’s Refund With A Disputed Tax Liability

Rivkin Radler LLP on 4/19/2024

Imagine the IRS notifies Taxpayer that they have an outstanding tax liability with respect to Tax Year, and that the agency intends to levy on Taxpayer’s property to collect the allegedly unpaid tax. Taxpayer challenges the...more

Brazilian IRS Program Incentivizes Disclosure of Certain Tax Liabilities

Mayer Brown on 4/5/2024

On April 3, 2024, the Brazilian Internal Revenue Service (“Brazilian IRS”) published Normative Instruction RFB No. 2,184 (“IN/RFB No. 2,184/2024“), regulating a special program to incentivize the voluntary disclosure of...more

IRS to Focus on High-Income Earners Who Have Not Filed Tax Returns Since 2017

Fox Rothschild LLP on 3/4/2024

The IRS expects to send out over 125,000 collection letters to high-income taxpayers who did not file one or more federal income tax returns between 2017 and 2021. As part of the new collection initiative, approximately...more

Avisos De Cobros Del IRS Se Reiniciarán En 2024

Foodman CPAs & Advisors on 1/12/2024

Avisos de Cobros del IRS se reiniciarán en 2024 así como un nuevo alivio de multas para aproximadamente 4.7 millones de personas, empresas y organizaciones exentas de impuestos a las que no se les envió un recordatorio...more

IRS Collection Notices To Re-Start In 2024

Foodman CPAs & Advisors on 1/12/2024

On 12/19/23, the IRS announced the restart of IRS collection notices as well as a new penalty relief for approximately 4.7 million individuals, businesses and tax-exempt organizations that were not sent an automated IRS...more

Move Over TikTok, the Tax Man May Be Snooping on You, Too

Kohrman Jackson & Krantz LLP on 6/2/2023

In a rare unanimous opinion, the U.S. Supreme Court recently confirmed that existing law allows the IRS to probe your bank records, without ever notifying you. Under the applicable statute, the Court concluded the IRS is not...more

Tax Court in Brief | Belton v. Comm'r | Seriously Delinquent Tax Debt” and IRS Requirement to Comply with Lien Procedure

Freeman Law on 1/30/2023

Summary: Petitioners, Willard Belton and Martha-Alexander Belton (Petitioners or Beltons) seeks review pursuant to section 7345(e), challenging the IRS’s certification to the Secretary of State that Petitioners had a...more

Tax Court in Brief | Adams v. Comm’r | “Seriously Delinquent Tax Debt” and Passport Revocation

Freeman Law on 1/30/2023

Summary: Petitioner, Blake M. Adams, seeks review pursuant to section 7345(e) of the IRS’s certification to the Secretary of State that Adams has a “seriously delinquent tax debt” related to tax years 2007, 2009, 2010, 2011,...more

Tax Court in Brief | Mattson v. Comm’r | Passport Revocation Notice for “Seriously Delinquent Tax Debt”; Limitations on Tax Liens

Freeman Law on 12/9/2022

Tax Litigation: The Week of December 5th, 2022, through December 9th, 2022 - Mattson v. Comm’r, T.C. Memo. 2022-118 | December 6, 2022 |Copeland, J. |Docket No. 16982-18P - Summary: Eric Mattson did not file income tax...more

TIGTA Finds IRS Is Not Always Following Procedures for Tax Liens

Freeman Law on 10/19/2022

In 2021, the Internal Revenue Service filed 212,251 Notices of Federal Tax Lien (“NFTLs”). To provide perspective, in 2019 (i.e., pre-COVID-19 pandemic), the IRS filed 543,604 NFTLs. The IRS is working on ramping up its...more

Tax Court in Brief | Goddard v. Comm'r | Collection Due Process, Penalties for Failure to Register a Tax Shelter

Freeman Law on 10/14/2022

Tax Litigation: The Week of September 19th, 2022, through September 22nd, 2022 Vorreyer v. Comm’r / Thoma v. Comm’r / Dowson v. Comm’r, T.C. Memo 2022-97| September 21, 2022 | Greaves, Judge | Dkt. Nos. (Consolidated)...more

Tax Court in Brief | Kotrides v. Commissioner | Collection Due Process, Abuse of Discretion, and Summary Judgment

Freeman Law on 7/8/2022

Tax Litigation: The Week of June 27th, 2022, through July 1st, 2022 Serna v Commissioner, T.C. Memo. 2022-66 | June 27, 2022 | Urda, J.| Dkt. No. 13202-19L Pedersen v. Commissioner, T.C. Summary Opinion 2022-11 | June 28,...more

Tax Court in Brief | Ezekwo v. Commissioner | Passport Revocation for Seriously Delinquent Tax Debt

Freeman Law on 6/16/2022

Tax Litigation: The Week of May 30th, 2022, through June 3rd, 2022 Ezekwo v Commissioner, T.C. Memo. 2022-54 | May 31, 2022 | Lauber, J.| Dkt. No. 15454-21P...more

Negotiating with the IRS Collection Division

Gray Reed on 12/17/2021

Once the IRS makes an assessment against a taxpayer, the taxpayer will receive several notices before the IRS takes enforced collection action....more

Taxpayers Must Pay Interest on Non-Existent Tax Debts

Davies Ward Phillips & Vineberg LLP on 11/5/2021

In The Bank of Nova Scotia v The Queen, the Tax Court of Canada (TCC) considered how to calculate arrears interest on an audit adjustment that is offset by a loss carryback. ...more

[Webinar] Freeman Law Legal and Tax Update - March 30th, 1:00 pm CT

Freeman Law on 3/24/2021

Join us as we discuss important developments during these unique times, and bring you up to speed on current initiatives. Business are still facing unprecedented challenges, and we are here to provide insights. During...more

Straddle-Year Tax Debts in Bankruptcy: Does the King Get Paid First? [More with McGlinchey, Ep. 14]

McGlinchey Stafford on 12/8/2020

The Internal Revenue Service is often a significant creditor in a bankruptcy proceeding, frequently taking priority over other creditors. In this episode, McGlinchey Tax attorney Douglas Charnas (Washington, DC) and Financial...more

Weekly IRS Roundup October 14 – October 18, 2019

McDermott Will & Emery on 10/21/2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 14 – October 18, 2019. October 15, 2019: The IRS published a news release that...more

Illinois Amnesty Programs Now Underway

McDermott Will & Emery on 10/2/2019

As previously announced, the Illinois Department of Revenue has begun a new amnesty program, running October 1 through November 15, 2019. All taxes paid to the Illinois Department of Revenue for taxable periods ending after...more

Seventh Circuit Upholds Lien Notice despite Incorrect Name

McDermott Will & Emery on 4/23/2019

When you do not pay your taxes, the Internal Revenue Service (IRS) has the power to file a “lien” on your property under Internal Revenue Code section 6321. The lien attaches “upon all property and rights to property, whether...more

Unpaid Federal Employment Taxes: The Government’s Chief Enforcement Priority

Burr & Forman on 10/29/2018

Businesses that have employees must pay wages and salaries to their employees, and the employer must collect federal employee income taxes and the employee’s share of social security (FICA) from these wages and salaries, add...more

IRS issues a “Tax Book”

Foodman CPAs & Advisors on 5/29/2018

During 2017, 245 million tax returns were processed by the IRS and more than $3.4 trillion in federal taxes was paid by individuals and businesses to the US Treasury. ...more

IRS is Looking more like a “Self-Serve” Financial Provider while still Targeting Collections

Foodman CPAs & Advisors on 6/26/2017

Since 2011, IRS has undergone $900 million in budget cuts and has reduced its number of auditors by approximately 25%. Nonetheless, IRS has its eye on the “collections” ball. The Agency has recently benefited from...more

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