I am often asked how long do I have to maintain records to protect myself against actions by the Int...
Notice of Right to a Collection Due Process Hearing – Is the IRS Trying to Hide the Ball?
The IRS must give a taxpayer written notice, sent by certified mail, at least 30 days before it take...
Late Returns and Discharging Taxes in Bankruptcy
If you want the chance to discharge your individual income taxes in bankruptcy, in Minnesota, file y...
Employment Taxes and Early Intervention
The IRS appears to be more serious about pursuing and prosecuting companies that do not pay their e...
The Complete Lawyer – Tax Controversies
Tom recently presented a seminar to Minnesota attorneys in which he shared some common questions ask...
IRS Summons – Defending Against the Summons
The United States Supreme Court is considering an investor’s objection to summonses issued by the ...
Awards of Attorneys Fees to the Plaintiff – When Are They Taxable as Wages?
Settlements in legal disputes between employers and employees can vary significantly depending on wh...
Relying On the Advice of an Accountant – When Does It Constitute Reasonable Cause to Abate a Late Filing Penalty?
The U.S. Supreme Court recently refused to hear an appeal from the Ninth Circuit Court of Appeals in...
Offer in Compromise – Is It An Option?
We regularly receive calls from people who tried to resolve their tax obligations through an Offer i...
I Owe the IRS Money – What Can I Do?
We often receive telephone calls and e-mails from individuals and businesses who have been contacted...
Claim for Refund of the Trust Fund Recovery Penalty
An individual assessed the Trust Fund Recovery Penalty (TFRP) has the option to pay just a portion o...
Section 530 – Reasonable Basis
This is the fourth article in a series dedicated to using Section 530 of the Revenue Act of 1978 as...
Section 530 – Substantive Consistency
This is the third article in a series dedicated to using Section 530 of the Revenue Act of 1978 as p...
Section 530 – Reporting Consistency
This is the second article in a series dedicated to using Section 530 of the Revenue Act of 1978 as ...
Effective Tax Administration (ETA) Offer – An Underutilized Option.
In her annual Report to Congress, Nina Olson , the Taxpayer Advocate, pointed out that the IRS is un...
Conservation Easements – Subordinating Mortgages
There are many tax and social benefits to gifting a conservation easement. Unfortunately, some taxpa...
Real Estate Professional – Maintaining Adequate Records
Doing well in a full time job is hard enough, but some people, for many reasons, spend significant t...
Relief for Businesses Using Independent Contractors: Section 530 is Still a Viable Option
This is the first article in a series dedicated to using Section 530 of the Revenue Act of 1978 as p...
Valuations Misstatements and the IRS Accuracy Penalty (IRC Section 6664(c))
I have been watching the tax cases dealing with building facade easements for insight into how the I...
Can I discharge income taxes in bankruptcy?
Yes, under the right circumstances. Income taxes (not trust-fund or withholding taxes) are discharge...