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Can the IRS reach an interest in real property held in a land trust? If so, what happens if the taxpayer sells the property? Can the IRS recoup the land from the new buyer or is the IRS limited to the proceeds received? The court addresses this in United States v. Harold, No. 2:18-cv-10223 (S.D.……
Category: Tax
Recover Money Paid to the IRS in Error
What if the IRS gets it wrong and then fails to respond to the taxpayer for several years. Can the IRS then agree with the taxpayer, but argue that the taxpayer responded late? The informal claim doctrine can help in these situations. The Chenette v. United States, No. 19-cv-02998-JCS (N.D. Cali. 2019) case provides an……
IRS Levy Does Not Attach to Future Payments
The IRS levy is one of the IRS’s primary methods for collecting unpaid taxes. But the levy power is not unlimited. The IRS levy can attach to some amounts held by third parties that are owed to the taxpayer. But… Read More The post IRS Levy Does Not Attach to Future Payments appeared first on Houston…
IRS Revises Passport Certification Process
Did you get a letter from the IRS about your passport? The IRS recently started sending these letters to taxpayers with unpaid tax debts. The letters have generated quite a bit of controversy, which caused the IRS to pause to reconsider how it handles this issue. Here is what you need to know about the…
M&A Finders Fee Not Deductible for Acquirer
If a company acquires another company and pays a finders fee to the party who connected the two for the sale, is the finders fee deductible by the acquirer? This question touches on whether an expense is deductible if the… Read More The post M&A Finders Fee Not Deductible for Acquirer appeared first on Houston Tax…
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…
Can the IRS Collect Gift Tax From Recipient After 14 Years?
If someone gives you property and then dies and more than ten years has passed since the gift, can the IRS sue you to collect the amount of the gift from you? Most would think the answer is a resounding… Read More The post Can the IRS Collect Gift Tax From Recipient After 14 Years? appeared…
Avoiding State Income Tax on Part-Time Residents
Sometimes you can’t avoid paying state income taxes. This is true for those who have no ties to any state other than a state that has an income tax. But for those who have ties to multiple states, they can… Read More The post Avoiding State Income Tax on Part-Time Residents appeared first on Houston Tax…