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Tax Liability Tax Refunds Tax Returns

Rivkin Radler LLP

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

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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

Bowditch & Dewey

Update Your 2024 Tax Withholding to Avoid Year-End Surprises

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Now that the 2023 tax filing season is underway, many taxpayers are having an unpleasant surprise when they file their tax return this year and find out they are getting a much smaller refund than they were expecting, or...more

Bowditch & Dewey

Massachusetts Tax Rebates to Begin November 1, 2022

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On October 31, 2022, the Massachusetts Department of Revenue (DOR) announced that tax refunds consisting of about $2.9 billion in excess tax revenue will begin on November 1, 2022....more

Bowditch & Dewey

Update Your Tax Withholdings to Avoid Year-End Surprises

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During the 2022 tax filing season, many taxpayers had an unpleasant surprise when they filed their tax return and found out they were getting a much smaller refund than they were expecting, or worse, had a balance due....more

Sheppard Mullin Richter & Hampton LLP

When Does Cryptocurrency Mining Create a Taxable Event? IRS Does Not Clarify

A couple rejected a refund settlement offer from the IRS over its tax treatment of tokens they earned from mining. Instead, the couple has sought formal adjudication on the issue from the federal courts. The government has...more

Gray Reed

Taxpayer’s Informal Claim for Refund of Taxes Paid and Offset by the IRS Denied on a Technicality

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Properly navigating the IRS labyrinth of rules and regulations is difficult and sometimes taxpayers fail to dot every “i” and cross every “t”. The results can sometimes be devastating for both individuals and small...more

Gray Reed

Taxpayer Wins Tax Refund Despite IRS Claims That The Taxpayer Used The Wrong Form

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Dealing with the IRS can be a dangerous labyrinth for the untrained taxpayer or their non-tax advisors. In a recent Federal court case, E. John Rewwer, et al. v. United States, the taxpayers filed the wrong form claiming a...more

Freeman Law

Protective Refund Claims: Preserving the Right to a Tax Refund

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When is a protective refund claim available?  Taxpayers often face uncertain outcomes in litigation or business transactions, giving rise to contingent tax refund claims.  For example, if a pending lawsuit ends in a favorable...more

Freeman Law

Executor Seeks Refund of Fiduciary Income Taxes, and The Application of Iqbal/Twombly to Defensive Pleadings in Tax Cases

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The executor of the Estate of Tamir Sapir is seeking a refund of more than $25 million of fiduciary income tax alleged to have been overpaid to the Internal Revenue Service (“IRS”). While the refund suit is currently teed up...more

Freeman Law

Missed Window—Taxpayer Loses Chance to Sue IRS on Claim for Refund

Freeman Law on

In The Merry Wives of Windsor, William Shakespeare penned the famous line: “Better three hours too soon than a minute too late.” And such sentiments of time are certainly true in the tax world. One minute late may have...more

Bilzin Sumberg

Emily S. Wilson et al. v. United States: Playing Battleship with the Internal Revenue Service

Bilzin Sumberg on

As many readers may know, Joseph Wilson (“Mr. Wilson”) was the settlor, tax owner, and beneficiary of a foreign trust. By virtue thereof, Mr. Wilson, as a U.S. citizen, had the requirement to file IRS Form 3520 and IRS Form...more

Oberheiden P.C.

Eleven of the IRS's Enforcement Priorities During the 2021 Tax Season

Oberheiden P.C. on

It is tax season once again. While the Internal Revenue Service (IRS) has extended this year’s filing deadline to May 17, 2021 for individuals, businesses must still file by April 15, and all U.S. taxpayers must ensure that...more

Gray Reed

ExxonMobil Discovers That Amended Tax Returns Are Dangerous

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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

Sullivan & Worcester

A Warm Welcome to the Tax Trotter

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Happy New Year and welcome to the Tax Trotter! What a year 2020 has been! Stock markets running high, travel low, Zoom reigning supreme with the blue light eyeglass filter becoming as popular as the anti-glare...more

BakerHostetler

Bad Debts - A State Income & Sales Tax Perspective

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It's no mystery that when times are hard, bad debts skyrocket. But how do businesses handle bad debts for state income and sales tax purposes? Matt Hunsaker hits the high points in this week's episode....more

McAfee & Taft

Maintaining Oklahoma tax incentives after COVID-19

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As businesses look to reopen and recover from the COVID-19 pandemic, they should be attentive to Oklahoma tax incentives previously awarded to them to ensure all requirements are met to continue to avail themselves of these...more

Burr & Forman

South Carolina Department of Revenue Issues Draft Guidance Announcing New Procedures For Handling Disputed State Tax Matters

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The South Carolina Department of Revenue (SCDOR or DOR) recently issued a draft of long-awaiting guidance overhauling DOR’s administrative practices concerning disputed tax audits, refunds, license revocations, and other...more

Jones Day

Jones Day Presents: LB&I Examination Strategies: Process Overview

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In 2016, the IRS's Large Business & International (LB&I) Division significantly altered its examination processes. In the first in a series of programs on LB&I strategies, Jones Day partner and tax litigator Chuck Hodges...more

Foodman CPAs & Advisors

Tax Fraud and the Element of Willfulness

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Tax fraud is often defined as an intentional wrongdoing on the part of a Taxpayer with the specific purpose of evading a tax known or believed owed. Tax fraud requires...more

Foodman CPAs & Advisors

IRS issues a “Tax Book”

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

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