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One of the most frequent disputes in IRS audits is whether the taxpayer had unreported income. This is income that the taxpayer failed to report on his or her income tax return. This typically involves cash a business or service provider received from clients. It may also include non-cash deposits into financial accounts. This “income……
Tax Articles
The Qualified Nonpersonal Use Vehicle
What Congress provides with one provision, it often takes away with another. This can result in legal challenges whereby the court creates exceptions. The exceptions can be modified and qualified by later legislation. This creates a labyrinth that one has to navigate to determine how an item is treated for federal income tax purposes. The……
Defeating the IRS Passport Certification Notice
Congress amended the code to allow the IRS to certify passports. This added another tool the IRS can use to get those with IRS back taxes to contact the IRS and, in some cases, to pay the IRS. As with most new laws, there are a number of open questions about how and when the……
The U.S. Tax Court: 1 Day Late
In many ways the U.S. Tax Court is a court and operates like other courts. But in other ways, the U.S. Tax Court is more akin to a government agency. This quasi-court status has raised a number of interesting issues about how to litigate a case in tax court and what standards apply and what……
IRS Collects Taxes Discharged in Bankruptcy
When the governmet confers a benefit, it invariably puts conditions on the benefit. Congress will often modify the conditions over time. The result can be a very nuanced set of rules that, to the uninitiated, can seem nonsensical and impossible to descipher. The rules that allow taxes to be discharged in bankruptcy fall into this……
The “Process” of the IRS Appeals Collection Hearing
The government establishes processes to carry out its essential functions. These processes handle a myriad of different types of cases and cases with nuanced fact patterns. These processes allow the government to process a high volume of cases. They often do so in bulk. The process is a like well-trodden path. The path may take……
Texas Taxes: Is an Owner Liable for Business Taxes?
When one thinks of Texas and taxes, the idea that Texas does not have an income tax may come to mind. This is true. Texas does not currently have an income tax. This does not mean that Texas does not collect taxes. Texas collects taxes–and a lot of taxes. This includes everything from property taxes……
The IRS’s Ability to Collect Foreign Assets
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……
Planning for Commercial Solar Tax Credits
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……
A New Beginning for Innocent Spouse Relief
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……
