Think Twice Before Handing Records to the IRS

There have been several lawsuits filed against the IRS for unlawful disclosure of taxpayer information. These include a suit filed by President Biden’s son, a lawsuit filed by the IRS against IRS contractor Charles Edward Littlejohn for leaking taxpayer information to news outlets–which apparently included former President Trump’s tax returns and returns for many other……

Accounting for Interest Deductions as a Tax Planning Option

Tax attorneys frequently come from an accounting background. This may seem like an unrelated skill, but it often plays a pivotal role in effective tax planning. The ability to navigate revenue and expenses and debits and credits not only ensures accurate financial reporting but also lays the foundation for strategic tax planning. Tax planning often……

Avoid Late IRS Installment Agreements

The concept of “judicial activism” refers to situations where judges do more than simply interpret existing laws. They venture into creating new laws or policies through their rulings. This encroaches on the legislative power of Congress, which creates the laws, and the executive agencies, which create policies to implement the law. This type of discretion……

Can You Still Owe Taxes on a Loan That’s 10 Years Old?

Our legal system allows people to move on from past obligations under certain circumstances. For example, people can discharge debts through bankruptcy, creditors have a limited amount of time to sue for unpaid debts, and even the IRS allows a fresh start for unpaid taxes. These laws strike a balance between allowing those who are……

Triggering Losses by Selling a Business: NQDC Example

Timing issues are one of the aspects of effective tax planning. There are scores of options for timing and tax deferral and recognition that depend on the taxpayer’s circumstances. For example, for corporate taxpayers, these timing issues may involve timing the receipt of income using the installment rules or the use of losses or foreign……

Tax Deductions for Non-Facilitating Costs for IP, M&A & Real Estate

One of the most common disputes between taxpayers and the IRS revolves around the question of whether certain expenses are deductible in the current year or need to be capitalized and recovered over time. This expense versus capitalization issue arises in various contexts. We have considered a number of these disputes on this site. It……

Charitable Tax Deductions & Bargain Sales

Our tax administration operates within the framework of a zero-sum game, leaving little flexibility for taxpayers who encounter technical foot faults or minor errors. Even when taxpayers have complied with most of the tax law requirements, a single misstep can potentially result in the disallowance of a tax benefit or deduction. This zero-sum approach, while……

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