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If a taxpayer signs an eFile form and there are defects in the information included on the form, does this invalidate the tax return that is eFiled? The IRS addresses this in CCA 201945027. This IRS memorandum addresses an eFile form where the person who signed the form for a partnership even though he had……
Tax Articles
Is IRS Bound by Social Security Disability Determination?
If the Social Security Administration determines that you are disabled, does the IRS have to accept that determination for tax purposes? It is one government is it not? The court considered this in Gentry v. United States, No. 3:18-cv-00581 (D. Nev. 2019) for the disability exception allowing for a longer period of time to file……
Records Needed for Partial Asset Dispositions
Taxpayers often overlook “partial asset dispositions.” Their tax advisers do too. This may be due to it being a depreciation issue that seems unimportant. It may also be that the partial asset disposition is a relatively new concept. Regardless, partial… Read More The post Records Needed for Partial Asset Dispositions appeared first on Houston Tax Attorneys:…
Limits on Amount of Restitution for Tax Crime
If you are convicted of a tax crime and ordered to pay restitution to the government, how is the amount of the restitution determined? Can the government make an estimate? What if third parties already paid the IRS? Do you… Read More The post Limits on Amount of Restitution for Tax Crime appeared first on San…
Voluntary Disclosure to IRS of Privileged Communication
The attorney-client privilege projects confidential communications with attorneys. It allows the attorney to avoid disclosing protected communications. But what if the attorney voluntarily discloses information and the disclosure is to the IRS about a tax matter? The court addresses this… Read More The post Voluntary Disclosure to IRS of Privileged Communication appeared first on Houston Tax…
Paying Personal Expenses from Corporate Bank Account
Can you avoid paying tax by paying your personal expenses from your corporate bank account? Is avoiding tax that easy? No, our system doesn’t work that way. The Moacir Santos v. Commissioner, T.C. Memo. 2019-148 explains how the IRS handles these situations. Facts & Procedural History The taxpayer owns a engineering and paving company. It……
Can the IRS Ignore the Legal Existence of a Corporation?
If a taxpayer forms a legal entity and it is taxed as a C corporation, can the IRS disregard the legal existence of the corporation and assess the corporation’s tax to the owner? The court addresses this in Russell v.… Read More The post Can the IRS Ignore the Legal Existence of a Corporation? appeared first…
The Timing Trap: Failed Installment Sales
What happens if you sell an asset and are to receive payments in the future, but your accountant fails to elect the installment method? Do you have to report the full amount of the gain in the year of sale?… Read More The post The Timing Trap: Failed Installment Sales appeared first on Houston Tax Attorneys:…
Arguing that the Tax Return You Filed is Incorrect
If your tax return is incorrect and you have pending tax litigation with the IRS, can you argue that the tax return is incorrect? What if the time period for filing an amended tax return is still open? Should the court consider the new argument or should it rely on the incorrect tax return? The……
Can IRS Rely on Third Party Reports to Identify Taxable Income?
If a third party collects monies for you and send you a report reflecting the monies but the reports show too much income, should you be taxed on the higher income or what you actually received? The Ghadiri-Asli v. Commissioner,… Read More The post Can IRS Rely on Third Party Reports to Identify Taxable Income? appeared…
