The IRS Summons & When the IRS Fails to Follow the Law

What happens if the law requires the IRS to provide notice to the taxpayer and the taxpayer to provide notice to the IRS and both parties fail to provide the notice? Can the government ignore its failure and enforce consequences for the taxpayer’s failure? The answer is “yes” when it comes to the IRS summons,…Continue…

Using Multiple PTINs to File Fraudulent Tax Returns

It can be difficult to be a tax preparer. The rules change just about every year. The IRS has increased its focus on identifying and punishing tax return preparers. This includes criminal sanctions for the tax return preparers. The enforcement actions often do not factor in the realities of the tax preparation business. The recent……

Qualifying for the Foreign Earned Income Exclusion

As tax attorneys in San Antonio, we see a lot of U.S. citizens whose oil-related jobs require they spend significant time overseas. The wages earned overseas can escape tax in the U.S. This is due to the foreign earned income exclusion. But this exclusion generates quite a few tax disputes with the IRS, which is…Continue…

S Corp Conversions: Watch out for Disappearing AAA

Small and medium-sized business can save quite a bit in taxes by using S corporations. But with this tax savings comes complexity. This complexity comes from how S corporations flow through profit and have the profit taxed on the individual… Read More The post S Corp Conversions: Watch out for Disappearing AAA appeared first on Houston…

Does Late Payment Tax Penalty Run from Extended Due Date?

If you file an extension for an estate tax return and pay the tax before the extended due date, can the IRS impose penalties for late payment? The court addresses this in Estate of Agnes R. Skeba v. United States, No. 3:17-cv-10231 (D.N.J. 2019). Facts & Procedural History The taxpayer is an estate. It’s estate……

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