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Internal Revenue Code (IRC) Tax Liens

Kilpatrick

Death, Taxes, and the Sale of Business Interests

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Introduction: What is Estate Tax and Who Has to Pay? Over 200 years have passed since Benjamin Franklin famously wrote, “in this world, nothing can be said to be certain, except for death and taxes.” This sentiment still...more

Rivkin Radler LLP

Transferee Liability for Estate Tax: The Downside of Being a Beneficiary

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Death of a Parent- In the context of a family-owned business, it is often the case that the matriarch or patriarch of the family is also the chief executive of the business. They may have founded the business, or they may...more

Freeman Law

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

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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

Freeman Law

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

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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

Freeman Law

TIGTA Finds IRS Is Not Always Following Procedures for Tax Liens

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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

Freeman Law

You Received an IRS CP504 Notice, Now What?

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The IRS sends a CP504 Notice when a taxpayer has failed to pay a balance owed. The CP504 Notice is a Notice of Intent to Levy issued pursuant to Section 6331(d) of the Internal Revenue Code. If a taxpayer fails to make...more

Freeman Law

The IRS and Nominee Liability

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Under the Internal Revenue Code, the IRS can satisfy a tax deficiency by imposing a lien on any “property” or “rights to property” belonging to the taxpayer.  The statutory language is broad and reaches virtually every...more

Freeman Law

Tax Court in Brief January 31 – February 4, 2022

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....more

Freeman Law

The Tax Court in Brief - February 2021

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of January 25 – January 29, 2021 - Costello v. Comm’r, T.C....more

Maynard Nexsen

Letters and Notices from the IRS are Coming – What You Need to Know

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Given the recent expiration of the IRS’s People First Initiative on July 15, the return of IRS employees to offices and service centers, and this news release reminding taxpayers that collection activities would start...more

Rosenberg Martin Greenberg LLP

COLLECTION—When Uncle Sam Crosses the Border: What is in the IRS International Collection Toolbox?

The Internal Revenue Service (“IRS”) faces many challenges when attempting to collect unpaid taxes from taxpayers with foreign assets who reside abroad (“international delinquent taxpayer” or “IDT”). Common obstacles include...more

McDermott Will & Emery

Sacked in Tax Court! Procedural Missteps by the IRS Leave the Government’s Blindside Exposed

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In Kearse v. Commissioner, T.C. Memo 2019-53, the Tax Court held the Internal Revenue Service (IRS) abused its discretion as part of the taxpayer’s Collection Due Process hearing (CDP hearing) because the Appeals officer...more

Miles & Stockbridge P.C.

Court Upholds Foreclosure on Taxpayer’s Primary Residence in Satisfaction of Federal Tax Lien

In United States v. Smith, 117 AFTR 2d 2016-XXXX (February 8, 2016), the U.S. District Court for the Western District of Washington allowed the Federal government to foreclose on the taxpayers’ primary residence in...more

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