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Taxpayers are able to dispute a tax liability before the IRS can take certain collection actions. But what if the IRS does not afford the taxpayer with a genuine opportunity to dispute the liability as required by law? The court addresses this in Dood v. Commissioner, T.C. Memo. 2019-107. Facts & Procedural History The taxpayer……
Tax Articles
The Importance of Accounting for C Corporation Expenses
It is important to keep accurate books and records. Accurate books and records can result in significant tax savings. This is particularly true for entrepreneurs who own more than one business. When one or more of these businesses are taxed… Read More The post The Importance of Accounting for C Corporation Expenses appeared first on Houston…
Does the IRS Have the Burden to Prove Constructive Dividends?
When a C corporation pays expenses for its shareholder, the payment can be subject to income tax for the shareholder as a constructive dividend. One defense is that the expenses for the C corporation were legitimate. Does the taxpayer have… Read More The post Does the IRS Have the Burden to Prove Constructive Dividends? appeared first…
Is a Taxpayer Liable for Interest if the IRS Delays an Audit?
Can the IRS fail to audit a taxpayer for several years and then, once it actually opens the audit, drag its feet for years and then charge the taxpayer interest retroactively back to the date the tax return was filed?… Read More The post Is a Taxpayer Liable for Interest if the IRS Delays an Audit?…
IRS Tax Debts from Retirement Account Distributions
Retirement account distributions typically trigger sizable tax liabilities. These liabilities often go unpaid, which results in unpaid tax debts and IRS collection enforcement actions. With careful planning, sometimes these taxes can be avoided. Tax on Retirement Account Distributions Most distributions from retirement accounts trigger income taxes. This includes distributions from IRAs and 401(k)s. The idea……
Reasonable Cause: Proving Reliance on a Tax Advisor
If you hire a competent tax advisor and end up having a late filed return, you may be able to avoid penalties for the late filing. But this is a defense. It is something that you, the taxpayer, have to… Read More The post Reasonable Cause: Proving Reliance on a Tax Advisor appeared first on Houston…
Is Reliance on a CPA Sufficient for a Late Filed Tax Form?
The IRS often turns a deaf ear to taxpayers who miss a filing deadline due to some action or inaction by their CPA or tax preparer. This is the case for late filing tax penalties. But what about a late… Read More The post Is Reliance on a CPA Sufficient for a Late Filed Tax Form?…
Taxpayer Cannot Recoup Attorney Travel Costs
If the IRS wrongfully denies your refund claim and you are successful in litigating the matter in court, you are entitled to recoup some of your court costs. But what about the taxpayer’s tax attorney’s travel costs? And what if… Read More The post Taxpayer Cannot Recoup Attorney Travel Costs appeared first on Houston Tax Attorneys:…
Cashing a Tax Refund Check for a False Return is a Crime
Cashing a tax refund check that was triggered by filing a false tax return is a crime. It is theft of government money. Theft of government money is different than tax evasion. The recent United States v. Box, No. 18-13935… Read More The post Cashing a Tax Refund Check for a False Return is a Crime…
CPA Penalized for Knowledge of Understatement
Sec. 6701 imposes a penalty for assisting another person in understating their tax liability. The Sec. 6701 penalty is not subject to a statute of limitations. The IRS can assess these penalties at any time, even years and decades after… Read More The post CPA Penalized for Knowledge of Understatement appeared first on Houston Tax Attorneys:…
