Articles

Articles

Practical writing on tax disputes, audits, appeals, collections, and tax planning.

  • IRS Revises Passport Certification Process

    Did you get a letter from the IRS about your passport? The IRS recently started sending these letters to taxpayers with unpaid tax debts. The letters have generated quite a bit of controversy, which caused the IRS to pause to reconsider how it handles this issue. Here is what you need to know about the… Read →

  • M&A Finders Fee Not Deductible for Acquirer

    If a company acquires another company and pays a finders fee to the party who connected the two for the sale, is the finders fee deductible by the acquirer? This question touches on whether an expense is deductible if the…  Read →

  • The IRS Summons & When the IRS Fails to Follow the Law

    What happens if the law requires the IRS to provide notice to the taxpayer and the taxpayer to provide notice to the IRS and both parties fail to provide the notice? Can the government ignore its failure and enforce consequences for the taxpayer’s failure? The answer is “yes” when it comes to the IRS summons,… Read →

  • Using Multiple PTINs to File Fraudulent Tax Returns

    It can be difficult to be a tax preparer. The rules change just about every year. The IRS has increased its focus on identifying and punishing tax return preparers. This includes criminal sanctions for the tax return preparers. The enforcement actions often do not factor in the realities of the tax preparation business. The recent… Read →

  • Qualifying for the Foreign Earned Income Exclusion

    As tax attorneys in San Antonio, we see a lot of U.S. citizens whose oil-related jobs require they spend significant time overseas. The wages earned overseas can escape tax in the U.S. This is due to the foreign earned income exclusion. But this exclusion generates quite a few tax disputes with the IRS, which is… Read →

  • Can the IRS Collect Gift Tax From Recipient After 14 Years?

    If someone gives you property and then dies and more than ten years has passed since the gift, can the IRS sue you to collect the amount of the gift from you? Most would think the answer is a resounding…  Read →

  • Avoiding State Income Tax on Part-Time Residents

    Sometimes you can’t avoid paying state income taxes. This is true for those who have no ties to any state other than a state that has an income tax. But for those who have ties to multiple states, they can…  Read →

  • S Corp Conversions: Watch out for Disappearing AAA

    Small and medium-sized business can save quite a bit in taxes by using S corporations. But with this tax savings comes complexity. This complexity comes from how S corporations flow through profit and have the profit taxed on the individual…  Read →

  • Does Late Payment Tax Penalty Run from Extended Due Date?

    If you file an extension for an estate tax return and pay the tax before the extended due date, can the IRS impose penalties for late payment? The court addresses this in Estate of Agnes R. Skeba v. United States, No. 3:17-cv-10231 (D.N.J. 2019). Facts & Procedural History The taxpayer is an estate. It’s estate… Read →

  • Final Regulations Issued: Leveraged Partnership Distributions Still Viable

    The “leveraged partnership distribution” or “disguised sale” is a common tax savings technique used by real estate owners. Taxpayers pushed the envelope with these transactions by using “bottom dollar guarantees.” This led to guidance from the government making it more…  Read →

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