From the Author Archive

Supreme Court Allows Maximum Penalty

The U.S. Supreme Court recently ruled that even though a taxpayer invested in a tax shelter based on advice that turned out to be incorrect, the IRS is still able to assess the maximum […]

U. S. Taxpayers With Foreign Assets Have Filing Obligations

The IRS continues to remind taxpayer of their foreign asset filing obligations.  The obligations apply to U.S. citizens, resident aliens, including those with dual citizenship, and those living abroad.  In fact, the filing deadline […]

Virtual Currency Treated As Property by IRS

The Internal Revenue Service recently released their views on the proper tax treatment of virtual currencies such as bitcoin.  These virtual currencies are often used as a medium of exchange for payment for goods […]

Responsible Person Liability For Payroll Taxes

The Internal Revenue Code (Section 7501) states that payroll taxes withheld from an employee’s paycheck are held in trust for the United States and must be paid to them.  Withholding these funds and then […]

IRS May Offer Penalty Relief Under OVDP

The IRS continues to collect revenue under its Offshore Voluntary Disclosure Program (OVDP).  To date it has brought in $5 billion in revenue.  The penalties are varied and can be severe.  Recently, the IRS […]

What…???…Good News From Congress???

Some good news from Capitol Hill just emerged. In a prior blog, we noted that tax credits/deductions expire each year but the number expiring in 2013 was HUGE and included such heavy hitters as […]

And the Audits Begin

By: Evan A. Nielsen With tax season now concluded, the questions typically turn to audits and their ramifications. And there are some surprising things happening already this year regarding audits. Here are just a […]

What I Learned From An IRS Appeals Officer

What I learned from an IRS Appeals Officer Over the years, I’ve had the opportunity to associate with IRS personnel at several levels. Each time, I’ve come away with additional insight as to the […]

IRS Ramps Up Use of Summonses to Gather Taxpayer Information

A recent uptick in IRS summons litigation indicates an increase by the Service’s use of summonses to gather information and accelerate investigations.  This has been confirmed in a speech given by IRS officials at […]

IRS Heads East on Tax Evasion Hunt.

The IRS cracked the bank secrecy laws of Switzerland and it is aggressively pursing tax evaders and their Swiss enablers.  But there has never been any reason why the IRS can’t head east and […]