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Natural disasters can be expensive. This is particularly true for those who own or have an interest in real estate. Our tax laws provide some relief through casualty loss deductions and theft loss deductions. But what happens when someone pays to repair property they don’t legally own? This question is particularly relevant when parents continue……
Tax Articles
Substantial Variance Doctrine for Informal Tax Refund Claims
Taxpayers often submit refund claims when they discover that they overpaid their taxes. Taxpayers usually do this by submitting a formal refund claim using the IRS’s prescribed forms. But this is not always required. In many cases, taxpayers will submit so-called “informal refund claims” to the IRS during the course of an IRS audit. The……
Section 179D Tax Deduction Claimed in Final Year
Architects and engineers who design energy-efficient government buildings can qualify for a Section 179D tax deduction. Technically, it is the building owner who qualifies, but since the government is the owner of the building and does not pay tax, our tax law allows the allocation of the deduction to the designer. This allocation provides an……
Immediate Expensing for Real Estate Costs
When a taxpayer has a capital outlay, they generally want to deduct the expense when the money leaves their bank account or when the liability is incurred. However, the accounting matching principle dictates that expenses should be deducted when the related income is received. The matching principle aligns the income and expense recognition. Our income……
Can the IRS Collect When the IRS Owes the Taxpayer?
The federal tax system provides various procedural safeguards to protect taxpayers while ensuring efficient tax collection. These protections become particularly important when taxpayers face immediate collection actions while simultaneously pursuing tax credits or refunds that could eliminate their tax debt. Many businesses have recently found themselves in this situation after filing amended returns to claim……
Evaluation of Valuations for Charitable Contributions
The valuation of property for charitable contribution deductions represents one of the most challenging areas of tax compliance for both practitioners and taxpayers. While the tax code encourages charitable giving through deductions, it also demands rigorous substantiation and accurate valuations to prevent abuse. For real estate donations in particular, determining the appropriate value requires careful……
When Can You Challenge Your Tax Liability in a CDP Hearing?
The Collection Due Process (“CDP”) hearing is often viewed as a last resort for taxpayers facing IRS Tax Collections. While these hearings provide important taxpayer protections, one of the most misunderstood aspects is when a taxpayer can challenge their underlying tax liability. Many taxpayers assume they can always dispute how much they owe during a……
IRS Changes Notice Requirement for Listed Transactions
When a taxpayer files a tax return reporting their income, the IRS gains insight into their earnings and can compare this information with similarly situated taxpayers. One might expect that this regular reporting would be sufficient for tax administration purposes. The IRS could simply identify and audit returns showing unusual drops in reported tax. This……
FBAR Penalties Are Unconstitutionally Excessive
Most tax penalties follow a simple logic. The bigger the tax problem, the bigger the penalty. For example, the civil fraud penalty is one of the most severe penalties in our tax code. This makes sense as fraud is the most severe thing that one can do wrong when it comes to taxes. The civil……
IRS Collection From Business Partner’s Property
Many business owners choose to acquire and operate their businesses with partners. This allows them to divide the responsibilities and share the risks and the rewards. But what happens when one business partner falls behind on their federal taxes? Could the tax-compliant partner’s share of the business and business assets be at risk? Can the……
