Articles

Articles

Practical writing on tax disputes, audits, appeals, collections, and tax planning.

  • Can IRS Rely on Third Party Reports to Identify Taxable Income?

    If a third party collects monies for you and send you a report reflecting the monies but the reports show too much income, should you be taxed on the higher income or what you actually received? The Ghadiri-Asli v. Commissioner,…  Read →

  • Whistleblower’s Claim Limited by IRS’s Discretion Not to Collect Tax

    If you turn in a tax cheat by filing a whistleblower claim with the IRS, what happens if the IRS does not realize the importance of the information received? Put another way, what if the IRS leaves money on the table by failing to assess the full amount for the taxpayer? Is the whistleblower entitled… Read →

  • 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 →

  • 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 →

  • 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 →

  • 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 →

  • 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 →

  • Final Regulations Issued: Leveraged Partnership Distributions Still Viable

    The “leveraged partnership distribution” or “disguised sale” is a common tax savings technique used by real estate owners. Taxpayers pushed the envelope with these transactions by using “bottom dollar guarantees.” This led to guidance from the government making it more…  Read →

  • The Broad Reach of the Economic Substance Doctrine

    Congress provides tax incentives to change taxpayer behavior. If a taxpayer changes their behavior to take advantage of the incentive, they have to do so carefully. The IRS and the courts can apply the economic substance doctrine to take away…  Read →

  • Documenting the Sec. 199a Rental Real Estate Safe Harbor

    We have previously considered the “trade or business” requirement for the Section 199a deduction. The government recently issued guidance to clarify when rental real estate activities can qualify for the deduction. While the guidance is needed, it adopts a record…  Read →

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