We often receive telephone calls and e-mails from individuals and businesses who have been contacted by the IRS for a tax obligation owing and they don’t know what to do. There are many options for dealing with these obligations. The correct option depends on the facts of the case. Unfortunately, too often, an individual or [...]
An individual assessed the Trust Fund Recovery Penalty (TFRP) has the option to pay just a portion of the assessment to gain access to a court. This is different from the requirement for income taxes, which calls for payment, in full, of the tax, penalty, and interest, before a court can hear the case. The [...]
This is the fourth article in a series dedicated to using Section 530 of the Revenue Act of 1978 as protection for businesses that have been using independent contractors, in good faith, but are now facing an IRS or State of Minnesota audit of that practice. Section 530 may be 34 years old, but it [...]
This is the third article in a series dedicated to using Section 530 of the Revenue Act of 1978 as protection for businesses that have been using independent contractors, in good faith, but are now facing an IRS or State of Minnesota audit of that practice. Section 530 may be 34 years old, but it [...]
This is the second article in a series dedicated to using Section 530 of the Revenue Act of 1978 as protection for businesses that have been using independent contractors, in good faith, but are now facing an IRS or State of Minnesota audit of that practice. Section 530 may be 34 years old, but it [...]
In her annual Report to Congress, Nina Olson , the Taxpayer Advocate, pointed out that the IRS is under-utilizing the Effective Tax Administration (ETA) Offer in Compromise (OIC) program. The IRS accepted an average of only 27 ETA OICs per year. The ETA program is designed as an alternative to the Doubt as to Collectibility [...]
There are many tax and social benefits to gifting a conservation easement. Unfortunately, some taxpayers are in too much of a hurry to make the contribution and do not complete all of the steps necessary to receive all of the tax benefits. The U. S. Tax Court, in Minnick and Lienhart v. Commissioner, T.C. Memo [...]
Doing well in a full time job is hard enough, but some people, for many reasons, spend significant time, energy, and money away from their “regular job” trying to build themselves a better future through real estate. They often feel like they spend every waking hour away from their regular job dealing with their real [...]
This is the first article in a series dedicated to using Section 530 of the Revenue Act of 1978 as protection for businesses that have been using independent contractors, in good faith, but are now facing an IRS or State of Minnesota audit of that practice. Section 530 may be 34 years old, but it [...]
I have been watching the tax cases dealing with building facade easements for insight into how the IRS and the courts are reacting to the significant deductions being taken by partners in real estate partnerships. These partnerships generally buy a building, develop it, and contribute a restrictive easement to an historic preservation nonprofit organization. (See [...]