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Tax Articles
Notes from our active practice — IRS audits, appeals, Tax Court litigation, and state and local tax matters. Summaries here link out to the full posts on our regional practice sites.
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Owe the IRS but Can’t Tap Home Equity to Pay?
A taxpayer falls behind on his taxes. Life happens. A spouse gets sick, a house goes into foreclosure, and the bills pile up. When the IRS sends a notice threatening to seize assets, the taxpayer says what feels obvious. I cannot pay this. That sounds like it should be the end of the matter. If……
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IRS Levy for a Debt It Already Agreed to Payment Over Time?
Most people think a tax debt is a tax debt. You owe the money, the IRS collects it, and that is the end of the story. But there is often more than one legal mechanism the government can use to collect the same dollars. Sometimes those mechanisms overlap. That overlap can create problems. Suppose the……
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Married Filing Separate, Community Property Reduction
Most small business owners think of their income as their own. You do the work. You bill the client. The money lands in your account. So when the IRS audits you and says you left income off your return, it feels like a problem that belongs to you alone. But that is not always how……
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Lose the Hobby Loss Fight, But Save the Farm
Most people who run a side venture know the IRS can be a difficult business partner. It happily takes a cut when the venture makes money. It often refuses to share in the pain when the venture loses money. The hobby loss rules are one of the tools the IRS uses to do this. So……
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When One Spouse’s Fraud Keeps the IRS Clock Open for Both
Married couples file a joint tax return because it is usually the easy choice. One return, one signature line for each spouse, one refund or one balance due. The convenience is real. So is the shared responsibility that comes with it. Most people understand that signing a joint return means both spouses are on the……
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When Are Cryptocurrency Staking Rewards Taxed?
Plenty of people who hold cryptocurrency never sell a single coin. They buy a token, leave it sitting in an account, and watch the balance grow. With some cryptocurrencies, that balance grows on its own. The platform “stakes” the tokens, and new tokens show up in the account every month. The owner does nothing. The……
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When Can the IRS Impose a Tax Penalty You Cannot Defend?
Taxpayers who get into a dispute with the IRS often assume that good faith will protect them. They relied on professionals. They read the materials. They believed the deduction was allowed at the time. So even if the deduction is later denied, they expect the penalty to go away because they were not careless and…
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When a Spouse’s Tax Evasion Conviction Does Not Bind You
A married couple files joint tax returns. Years later, one spouse is criminally convicted of tax evasion. The IRS then comes after both of them for the back taxes and a fraud penalty. Can the spouse who was not convicted fight the fraud finding if she was never charged with anything and never set foot……
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What If You Don’t Show Up to Your CDP Hearing?
You get a Final Notice of Intent to Levy for a year that you don’t feel that you owe the tax. The IRS made a mistake. You file the Form 12153 to request a Collection Due Process hearing because that’s what the letter says to do. The IRS assigns a settlement officer. She sends you…
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Can a Missing Statement in a Donation Letter Cost You the Entire Deduction?
Donating land to a city seems like a straightforward charitable act. You find a piece of property, decide to give it away, get an appraisal, file the paperwork, and claim the deduction. For many taxpayers, the assumption is that as long as the donation actually happened and the value is reasonable, the deduction should stand.…
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