Category: Houston

One of the most frequent disputes in IRS audits is whether the taxpayer had unreported income. This is income that the taxpayer failed to report on his or her income tax return. This typically involves cash a business or service provider received from clients. It may also include non-cash deposits into financial accounts. This “income……

What Congress provides with one provision, it often takes away with another. This can result in legal challenges whereby the court creates exceptions. The exceptions can be modified and qualified by later legislation. This creates a labyrinth that one has to navigate to determine how an item is treated for federal income tax purposes. The……

In many ways the U.S. Tax Court is a court and operates like other courts. But in other ways, the U.S. Tax Court is more akin to a government agency. This quasi-court status has raised a number of interesting issues about how to litigate a case in tax court and what standards apply and what……

The government establishes processes to carry out its essential functions. These processes handle a myriad of different types of cases and cases with nuanced fact patterns. These processes allow the government to process a high volume of cases. They often do so in bulk. The process is a like well-trodden path. The path may take……

When one thinks of Texas and taxes, the idea that Texas does not have an income tax may come to mind. This is true. Texas does not currently have an income tax. This does not mean that Texas does not collect taxes. Texas collects taxes–and a lot of taxes. This includes everything from property taxes……

Those who have unpaid taxes owed to the IRS may have assets located in foreign countries. If the IRS cannot collect from assets located in the United States, it may seek to collect from foreign assets. This is often a very difficult task. While the IRS has a number of tools to collect from foreign……

The solar tax credit can significantly reduce Federal income taxes. Congress has recently reaffirmed its desire to spur these investments to curb reliance on foreign energy and to help the environment. As with most tax incentives, such as the research tax credit, there are a number of rules that have to be followed to be……

The Taxpayer First Act of 2019 made several changes that impact how tax cases are handled. We are just now seeing some of these changes play out administratively and in court. The recent Bacigalupi v. Commissioner, Docket No. 20480-21 (U.S. Tax Court 2022) is an example of this. It is an innocent spouse case that……

Generally, when it comes to civil matters, state and Federal law includes various “statutes of limitations” and “discovery rules.” The statute of limitations rules say that a claim has to be filed within a certain time period. The discovery rules say that the time period for the statute starts to run when the claim is……

We know that we can take steps to minimize our taxes. Our tax laws allow for this and, on review, the courts have made this clear. Tax penalties are usually the problem with taking tax positions in situations that are not entirely clear. Taxpayers who find themselves having to make decisions in these gray areas……