Relying on Advice From the IRS

IRS employees often give bad and incorrect tax advice. There are numerous examples of this in reported tax cases. Unlike advice provided by licensed professionals, such as tax attorneys, one generally cannot prevail in a malpractice suit against the IRS. That leaves the question as to whether bad or incorrect advice from the IRS can……

IRS Says Congress’ Penalty Relief Not Available

To be viable, businesses have to pay for their operations and, after-tax, produce a profit or return. The tax burden can make it very difficult to produce a profit. This is particularly true when sales taxes and payroll taxes are considered. The sales tax is imposed on the transfer of property (and in some states……

Hospital Administrator Owes Trust Fund Penalty

Employment taxes can be deadly for businesses. Once a business gets behind, it can be impossible to catch up. Those operating a failing or struggling business may feel that using employment taxes as a short-term loan from the IRS is justified. The thinking may be that they are needed to keep employees employed, to save……

Contribution to Corporation, then Sale of the Corporation

Most income tax planning involves questions about income, deductions or credits, character, or timing, or some combination of these questions. When viewed from these categories, even simple transactions can present tax planning opportunities. The contribution of property to a corporation by its shareholder is an example. A contribution triggers taxable income to the shareholder. Our……

Charter Boat Expenses are Miscellaneous Itemized Deductions

We live in a complex society. Even common activities can be exceedingly complex. Take a charter boat operation, for example. One has to consider the various laws for registering the boat; laws that dictate where and when the boat can operate; the laws governing the crew and its activities; and financing and loan and insurance…Continue…

Factors Showing Innocent Spouse Relief

The IRS has wide discretion in how it administers our tax laws. This discretion is power in its purest sense. This power can be wielded to destroy hard-won reputations, careers, and fortunes and it can even cost individuals their freedom. These powers can come from ambiguities in our laws. They can come from restrictions in…Continue…

Rental Tax Losses for Those With Irregular Hours

Tax cases are interesting in that they apply a fairly well-developed set of rules to varying fact patterns. These varying fact patterns can result in surprising, and often unintended, consequences. The more complex the tax law in question, the more likely it is that the outcome will be something other than what Congress may have…Continue…

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