Category: Austin

Cryptocurrencies, a type of digital asset, can be a valuable source of tax losses. In fact, harvesting tax losses at or near the end of the year is a well-recognized tax planning strategy. This entails selling crypto positions that have sustained losses and immediately buying them back. This is not available for other assets, such……

In recent years, the U.S. government has taken steps to increase enforcement measures to allow the IRS to collect delinquent taxes. This includes adding Sec. 7345 to allow the IRS and U.S. State Department to revoke or deny passports of individuals with seriously delinquent tax debts. In order to revoke or deny a passport, the……

Innocent spouse relief is a complex and nuanced area of tax law that can be difficult to navigate. In order to successfully file a claim, one must have a thorough understanding of the rules and requirements. One example of this complexity is found in Section 6015(c), which does not require that the innocent spouse not……

The IRS has a lot of power. This power stems from the broad Congressional grant of authority to examine books and records to enforce our tax laws. Since taxes impact every individual and business for every transaction (and even inactions), this allows the IRS to audit and inquire into just about anything it wants to.……

Congress amended the code to allow the IRS to certify passports. This added another tool the IRS can use to get those with IRS back taxes to contact the IRS and, in some cases, to pay the IRS. As with most new laws, there are a number of open questions about how and when the……

When the governmet confers a benefit, it invariably puts conditions on the benefit. Congress will often modify the conditions over time. The result can be a very nuanced set of rules that, to the uninitiated, can seem nonsensical and impossible to descipher. The rules that allow taxes to be discharged in bankruptcy fall into this……

Indifference. It is generally defined as “lack of interest, concern, or sympathy.” Those who are unfortunate enough to work with the government employees to resolve a case or matter often have a profound understanding of this term. This is true of just about every government function–be it local, state, or federal. When it comes to……

The IRS has a track record of halting collection actions when there is a disaster or other major event. As tax attorneys in Austin we saw this in the aftermath of the Hurricane Harvey storms. While a temporary stop to collections can be helpful, it can also cause other problems. If you owe back taxes……

The federal sentencing guidelines help the courts set criminal sentences. These guidelines have to be considered when deciding whether to accept a plea agreement and how to handle the trial. The recent United States v. Kushimo, No. 18-3222 (3d. Cir. 2019), case provides an opportunity to consider two of the sentencing enhancements that often apply……

If the Social Security Administration determines that you are disabled, does the IRS have to accept that determination for tax purposes? It is one government is it not? The court considered this in Gentry v. United States, No. 3:18-cv-00581 (D. Nev. 2019) for the disability exception allowing for a longer period of time to file……