New IRS Appeals Procedures for Tax Controversies

The IRS administrative function plays a critical role in our tax administration system. The appeals process settles a majority of all tax disputes. It does so using processes and procedures that have developed over many years. To the uninitiated who have not experienced the IRS appeals process, the process can be confusing and, unfortunately, the… …

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Overcoming the IRS’s Constructive Dividends Argument

Those who own C corporations have to be careful about what amounts are paid out to or benefit the corporate shareholders. This is particularly true for closely held and family corporations. On audit, the IRS will often assert that these distributions are constructive dividends. This is usually a bad answer for taxpayers as it increases… …

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Married Filing Separate Spouse Liable for Tax

Marriage presents a number of difficult tax questions. One question is whether both spouses can be held liable when they file separately and one spouse fails to pay their taxes. This is a common marriage tax question that we are asked. One might think that the married filing separate status fully protects the other spouse.… …

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When Withdrawing IRS Tax Lien Facilitates Collection

The IRS’s collection efforts can impact different taxpayers differently. While the IRS has broad collection powers, there are some taxpayers who are largely immune from the IRS’s collection efforts. This varied impact is partly due to the range of collection tools Congress has provided to the IRS. The IRS lien notice provides an example. Many… …

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IRA Excess Contribution Tax for Stock Sale

There are a lot of unanswered questions when it comes to the tax rules for IRAs and other qualified plans. IRAs and qualified plans can shelter a significant amount of income from tax. Defined benefit plans are an example. A business owner can contribute and shelter up to $245,000 in these plans in 2022. This… …

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