Category: Houston

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……

One of the tax benefits of partnerships is that they are flexible. The parties can agree to differing terms and the values and dollars associated with those terms can be trued-up in subsequent years. The allocation of profit and loss provisions provides an example. Depending on their agreement, the parties can allocate profits and losses……

The IRS is tasked with enforcing our tax laws. The task should be to ensure “substantial compliance” by taxpayers. But all too often the audit process is nothing more than the IRS examining a handful of go-to-adjustment issues. These go-to-adjustment issues involve tax laws that Congress passed that leave room for interpretation. These issues often……

What do you do if a loved one is under audit by the IRS and then dies before the audit is closed? Imagine that the IRS issues a Notice of Deficiency to the taxpayer. Do you have the right to petition the U.S. Tax Court for the taxpayer? The court recently addressed this in Sanders……

Justice is not a word that is often mentioned in tax cases. While justice may be handed out in the opinions, the term “justice” isn’t usually expressly stated in the opinion or in the rules that the courts go by. There are exceptions. One exception is in the rules that allow IRS attorneys to raise……

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……