Ben Wagner – Page 3 – Wagner Tax Law

Winning A Tax Battle, But Losing the Tax War

A recent U.S. Tax Court decision in Barker v. Comm’r of Internal Revenue, T.C. Memo. 2018-67 exemp...

May 9, 2018Ben WagnerCategories: Ben Wagner, Trust Fund Recovery PenaltyTags: Internal Revenue Service, IRS attorney minneapolis, IRS attorney mn, IRS attorney twin cities, IRS officer liability, IRS penalty trust, IRS trust fund, Metro MN Tax Lawyer, Minneapolis Tax Attorney, Minneapolis Tax Lawyer, minnesota tax, MN Tax Attorney, officer liability, st. paul tax, st. paul tax attorney, tax attorney mn, tax lawyer mn, trust fund penalty, trust fund recovery pen, Trust Fund Recovery Penalty, Trust Fund Recovery Penalty IRS, twin cities tax, Twin Cities Tax Attorney, Twin Cities Tax Lawyer

Does the Internal Revenue Service’s “willfulness” standard in Trust Fund Recovery Penalty cases include a “reasonable cause” defense?

The recent Sixth Circuit decision in Bibler v. U.S., 2018 WL 1911249, may mark an evolution of the d...

March 27, 2018Ben WagnerCategories: Ben Wagner, Collection OptionsTags: California tax lawyer, CDP Hearing, chicago tax attorney, collection due process hearing irs, getting information from the IRS, illinois tax attorney, in person visit irs, installment agreement request, Internal Revenue Service, iowa tax attorney, irs collection letter, irs home visit, Metro MN Tax Lawyer, Minneapolis Tax Attorney, Minneapolis Tax Lawyer, minnesota tax, MN Tax Attorney, north dakota tax attorney, Offer in Compromise, oic irs, south dakota tax attorney, st. paul tax, st. paul tax attorney, st. paul tax lawyer, tax attorney mn, tax lawyer mn, twin cities tax, Twin Cities Tax Attorney, Twin Cities Tax Lawyer, wisconsin tax attorney

IRS Adopts The In-Person Approach

The Internal Revenue Service (IRS) had an interesting New Year’s resolution for 2018: more in-pers...

January 28, 2018Ben WagnerCategories: Ben Wagner, Collection OptionsTags: IRS attorney, IRS collections minnesota, IRS offer in compromise mn, IRS tax attorney, Minneapolis Tax Attorney, Minneapolis Tax Lawyer, minnesota irs case, minnesota tax, MN Tax Attorney, st. paul tax, st. paul tax attorney, st. paul tax lawyer, tax attorney mn, tax lawyer mn, twin cities tax, Twin Cities Tax Attorney, Twin Cities Tax Lawyer

The IRS Adds Passport Revocation To Its Collections Arsenal

On January 16, 2018, the Internal Revenue Service (IRS) issued a press release emphasizing that taxp...

May 31, 2017Ben WagnerCategories: Ben Wagner, FOIA and GDPATags: FOIA and GDPA, Freedom of Information Act, GDPA, getting information from Minnesota Revenue, getting information from the IRS, Government Data Practices Act, IRS information, MDR, MDR information, Metro MN Tax Lawyer, minneapolis tax, Minneapolis Tax Attorney, Minneapolis Tax Lawyer, minnesota tax, MN Tax Attorney, sd tax lawyer, st. paul tax, st. paul tax attorney, st. paul tax lawyer, tax attorney mn, tax lawyer mn, twin cities tax, Twin Cities Tax Attorney, Twin Cities Tax Lawyer, wi tax lawyer

FOIAs and GDPAs: How Requests for Information Can Help Practitioners Resolve Cases with the IRS or DOR

This is the sixth article in the Freedom Of Information Act Requests (FOIAs) and Government Data Pra...

April 15, 2017Ben WagnerCategories: Ben Wagner, FOIA and GDPATags: FOIA and GDPA, Freedom of Information Act, GDPA, getting information from Minnesota Revenue, getting information from the IRS, Government Data Practices Act, IRS information, MDR, MDR information, Metro MN Tax Lawyer, minneapolis tax, Minneapolis Tax Attorney, Minneapolis Tax Lawyer, minnesota tax, MN Tax Attorney, sd tax lawyer, st. paul tax, st. paul tax attorney, st. paul tax lawyer, tax attorney mn, tax lawyer mn, twin cities tax, Twin Cities Tax Attorney, Twin Cities Tax Lawyer, wi tax lawyer

FOIAs and GDPAs: How Requests for Information Can Help Practitioners Resolve Cases with the IRS or DOR

This is the fifth article in the Freedom Of Information Act Requests (FOIAs) and Government Data Pra...

February 3, 2017Ben WagnerCategories: Ben Wagner, FOIA and GDPATags: CA tax lawyer, California tax lawyer, FOIA and GDPA, Freedom of Information Act, GDPA, getting information from Minnesota Revenue, getting information from the IRS, Government Data Practices Act, IRS information, MDR, MDR information, Metro MN Tax Lawyer, minneapolis tax, Minneapolis Tax Attorney, Minneapolis Tax Lawyer, minnesota tax, MN Tax Attorney, sd tax lawyer, st. paul tax, st. paul tax attorney, st. paul tax lawyer, tax attorney mn, tax lawyer mn, twin cities tax, Twin Cities Tax Attorney, Twin Cities Tax Lawyer, wi tax lawyer

FOIAs and GDPAs: How Requests for Information Can Help Practitioners Resolve Cases with the IRS or DOR

This is the fourth article in the Freedom Of Information Act Requests (FOIAs) and Government Data Pr...

September 13, 2016Ben WagnerCategories: Ben Wagner, FOIA and GDPATags: CA tax lawyer, California tax lawyer, FOIA and GDPA, Freedom of Information Act, GDPA, getting information from Minnesota Revenue, getting information from the IRS, Government Data Practices Act, IRS information, MDR, MDR information, Metro MN Tax Lawyer, Minneapolis Tax Attorney, Minneapolis Tax Lawyer, minneapolis tqax, minnesota tax, MN Tax Attorney, sd tax lawyer, st. paul tax, st. paul tax attorney, st. paul tax lawyer, tax attorney mn, tax lawyer mn, twin cities tax, Twin Cities Tax Attorney, Twin Cities Tax Lawyer, wi tax lawyer

FOIAs and GDPAs: How Requests for Information Can Help Practitioners Resolve Cases with the IRS or DOR

This is the third article in the Freedom Of Information Act Requests (FOIAs) and Government Data Pra...

July 6, 2016Ben WagnerCategories: Ben Wagner, FOIA and GDPATags: CA tax lawyer, California tax lawyer, FOIA and GDPA, Freedom of Information Act, GDPA, getting information from Minnesota Revenue, getting information from the IRS, Government Data Practices Act, IRS information, MDR, MDR information, Metro MN Tax Lawyer, Minneapolis Tax Attorney, Minneapolis Tax Lawyer, minneapolis tqax, minnesota tax, MN Tax Attorney, sd tax lawyer, st. paul tax, st. paul tax attorney, st. paul tax lawyer, tax attorney mn, tax lawyer mn, twin cities tax, Twin Cities Tax Attorney, Twin Cities Tax Lawyer, wi tax lawyer

FOIAs and GDPAs: How Requests for Information Can Help Resolve Cases with the IRS or MDR

This is the second article in the Freedom Of Information Act Requests (FOIAs) and Government Data Pr...

June 1, 2016Ben WagnerCategories: Appeals, Audits, Ben Wagner, FOIA and GDPATags: FOIA and GDPA, Freedom of Information Act, GDPA, getting information from Minnesota Revenue, getting information from the IRS, Government Data Practices Act

FOIAs and GDPAs: How Requests for Information Can Help Resolve Cases with the IRS or MDR

This is the first article in the Freedom Of Information Act Requests (FOIAs) and Government Data Pra...

May 6, 2014Ben WagnerCategories: Ben Wagner, FBARTags: 2011 OVD Program, 2012 OVD Program, Collection Information Statement for Businesses, Collection Information Statement for Wage Earners and Self-Employed Individuals, disclosure FBAR, FBAR, FBAR controversey, FBAR disclosure, FBAR dispute, FBAR penalties, FBAR program, foreign bank account, Foreign Bank Account Reporting, Form 3520, Form 3520-A, Form 433-A, Form 433-A FBAR, Form 433-B, Form 433-B FBAR, Form 5471, Form 5472, Form 8865, Form 926, Form-B FBAR, how to report a foreign bank account, Internal Revenue Service’s (IRS’s) Offshore Voluntary Disclosure Program (OVD Program), Isle of Mann Tax Treaty, Metro Minnesota Tax Attorney, Metro MN Tax Attorney, Metro MN Tax Lawyer, Minneapolis IRS Tax Audit, Minneapolis Tax Attorney, Minneapolis Tax Firm, Minneapolis Tax Lawyer, Minnesota IRS Audit, Minnesota Tax Appeal, Minnesota Tax Attorney, Minnesota Tax Audit, Minnesota Tax Firm, Minnesota Tax Lawyer, MN Tax Attorney, MN Tax Firm, MN Tax Lawyer, Offshore Voluntary Disclosure Program (OVD Program), OVD Program, Quiet Disclosure, quiet disclosure FBAR, quiet FBAR, report a foreign bank account, Report of Foreign Bank and Financial Account, Report of Foreign Bank and Financial Account (FBAR), reporting a bank account abroad, States of Guernsey Tax Treaty, States of Jersey Tax Treaty, Twin Cities, Twin Cities Tax Attorney, Twin Cities Tax Lawyer

Explaining the Basics of the Quiet Disclosure of an FBAR

This is the sixth article in the Offshore Voluntary Disclosure Program (OVDP) Frequently Asked Quest...

April 17, 2014Ben WagnerCategories: Ben Wagner, FBARTags: 2011 OVD Program, 2012 OVD Program, Collection Information Statement for Businesses, Collection Information Statement for Wage Earners and Self-Employed Individuals, FBAR, FBAR controversey, FBAR disclosure, FBAR dispute, FBAR penalties, FBAR program, foreign bank account, Foreign Bank Account Reporting, Form 3520, Form 3520-A, Form 433-A, Form 433-A FBAR, Form 433-B, Form 433-B FBAR, Form 5471, Form 5472, Form 8865, Form 926, Form-B FBAR, how to report a foreign bank account, Internal Revenue Service’s (IRS’s) Offshore Voluntary Disclosure Program (OVD Program), Isle of Mann Tax Treaty, Metro Minnesota Tax Attorney, Metro MN Tax Attorney, Metro MN Tax Lawyer, Minneapolis IRS Tax Audit, Minneapolis Tax Attorney, Minneapolis Tax Firm, Minneapolis Tax Lawyer, Minnesota IRS Audit, Minnesota Tax Appeal, Minnesota Tax Attorney, Minnesota Tax Audit, Minnesota Tax Firm, Minnesota Tax Lawyer, MN Tax Attorney, MN Tax Firm, MN Tax Lawyer, Offshore Voluntary Disclosure Program (OVD Program), OVD Program, report a foreign bank account, Report of Foreign Bank and Financial Account, Report of Foreign Bank and Financial Account (FBAR), reporting a bank account abroad, States of Guernsey Tax Treaty, States of Jersey Tax Treaty, Twin Cities, Twin Cities Tax Attorney, Twin Cities Tax Lawyer

Explaining the Internal Revenue Service’s FBAR Penalty Structure

This is the fifth article in the Offshore Voluntary Disclosure Program (OVDP) Frequently Asked Quest...

March 28, 2014Ben WagnerCategories: FBARTags: 2011 OVD Program, 2012 OVD Program, Collection Information Statement for Businesses, Collection Information Statement for Wage Earners and Self-Employed Individuals, FBAR, FBAR controversey, FBAR disclosure, FBAR dispute, FBAR penalties, FBAR program, foreign bank account, Foreign Bank Account Reporting, Form 3520, Form 3520-A, Form 433-A, Form 433-A FBAR, Form 433-B, Form 433-B FBAR, Form 5471, Form 5472, Form 8865, Form 926, Form-B FBAR, how to report a foreign bank account, Internal Revenue Service’s (IRS’s) Offshore Voluntary Disclosure Program (OVD Program), Isle of Mann Tax Treaty, Metro Minnesota Tax Attorney, Metro MN Tax Attorney, Metro MN Tax Lawyer, Minneapolis IRS Tax Audit, Minneapolis Tax Attorney, Minneapolis Tax Firm, Minneapolis Tax Lawyer, Minnesota IRS Audit, Minnesota Tax Appeal, Minnesota Tax Attorney, Minnesota Tax Audit, Minnesota Tax Firm, Minnesota Tax Lawyer, MN Tax Attorney, MN Tax Firm, MN Tax Lawyer, Offshore Voluntary Disclosure Program (OVD Program), OVD Program, report a foreign bank account, Report of Foreign Bank and Financial Account, Report of Foreign Bank and Financial Account (FBAR), reporting a bank account abroad, States of Guernsey Tax Treaty, States of Jersey Tax Treaty, Twin Cities, Twin Cities Tax Attorney, Twin Cities Tax Lawyer

Explaining the Internal Revenue Service’s FBAR Penalty Structure

This is the fourth article in the Offshore Voluntary Disclosure Program (OVDP) Frequently Asked Ques...

March 7, 2014Ben WagnerCategories: FBARTags: 2011 OVD Program, 2012 OVD Program, Collection Information Statement for Businesses, Collection Information Statement for Wage Earners and Self-Employed Individuals, FBAR, FBAR controversey, FBAR disclosure, FBAR dispute, FBAR penalties, FBAR program, foreign bank account, Foreign Bank Account Reporting, Form 3520, Form 3520-A, Form 433-A, Form 433-A FBAR, Form 433-B, Form 433-B FBAR, Form 5471, Form 5472, Form 8865, Form 926, Form-B FBAR, how to report a foreign bank account, Internal Revenue Service’s (IRS’s) Offshore Voluntary Disclosure Program (OVD Program), Isle of Mann Tax Treaty, Offshore Voluntary Disclosure Program (OVD Program), OVD Program, report a foreign bank account, Report of Foreign Bank and Financial Account, Report of Foreign Bank and Financial Account (FBAR), reporting a bank account abroad, States of Guernsey Tax Treaty, States of Jersey Tax Treaty

Understanding the Basics of the IRS’s Offshore Voluntary Disclosure Program

This is the third article in a series regarding Frequently Asked Tax Questions relating to the Inter...

February 15, 2014Ben WagnerCategories: FBARTags: 2011 OVD Program, 2012 OVD Program, Collection Information Statement for Businesses, Collection Information Statement for Wage Earners and Self-Employed Individuals, FBAR, FBAR controversey, FBAR disclosure, FBAR dispute, FBAR penalties, FBAR program, foreign bank account, Foreign Bank Account Reporting, Form 433-A, Form 433-A FBAR, Form 433-B, Form 433-B FBAR, Form-B FBAR, how to report a foreign bank account, Internal Revenue Service’s (IRS’s) Offshore Voluntary Disclosure Program (OVD Program), Isle of Mann Tax Treaty, Offshore Voluntary Disclosure Program (OVD Program), OVD Program, report a foreign bank account, Report of Foreign Bank and Financial Account, Report of Foreign Bank and Financial Account (FBAR), reporting a bank account abroad, States of Guernsey Tax Treaty, States of Jersey Tax Treaty

Understanding the Basics of the IRS’s Offshore Voluntary Disclosure Program

This is the second article in a series regarding Frequently Asked Tax Questions relating to the Inte...

January 22, 2014Ben WagnerCategories: FBARTags: 2011 OVD Program, 2012 OVD Program, FBAR, FBAR controversey, FBAR disclosure, FBAR dispute, FBAR penalties, FBAR program, Internal Revenue Service’s (IRS’s) Offshore Voluntary Disclosure Program (OVD Program), Isle of Mann Tax Treaty, Offshore Voluntary Disclosure Program (OVD Program), OVD Program, Report of Foreign Bank and Financial Account, Report of Foreign Bank and Financial Account (FBAR), States of Guernsey Tax Treaty, States of Jersey Tax Treaty

Understanding the Basics of the IRS’s Offshore Voluntary Disclosure Program

This is the first article in a series regarding Frequently Asked Tax Questions relating to the Inter...

April 22, 2013Ben WagnerCategories: PenaltiesTags: failure to file penalty, file your tax return, I.R.C. 6012, I.R.C. 6081, I.R.C. 6151, I.R.C. 6161, I.R.C. 6651, importance of filing, Internal Revenue Service, IRS failure to file penalty., IRS late filing, IRS Penalties, IRS penalty, Late filing penalty, late payment penalty, Should I File My Federal Individual Income Tax Return Even If I Have A Balance Due?, when should i file my tax return

Should I File My Federal Individual Income Tax Return Even If I Have A Balance Due?

A common misperception for taxpayers is that by refraining from filing, they will buy themselves tim...

March 14, 2013Ben WagnerCategories: Settlements and VerdictsTags: abuse settlement tax, income tax settlement, individual income tax settlement abuse, IRC 104, IRC 104(a)(2), Sexual abuse, sexual abuse tax implications, Small Business Job Protection Act, tax implications settlement, taxation of settlements, taxation of settlements from sexual abuse cases

Are Settlements Compensating for Sexual Abuse Excluded from Gross Income?

There is one important question to ask when evaluating whether settlement proceeds compensating for ...

February 22, 2013Ben WagnerCategories: LevyTags: 6331, 7429, CDP Hearing, Collection Due Process Hearing, Collection Due Process or Equivalent Hearing., Internal Revenue Service jeopardy levy, IRC 6331, IRC 7429, IRS Appeals Office, IRS jeopardy assessment, IRS jeopardy levy, IRS', Jeopardy assessment, jeopardy levy, no notice levy

The Jeopardy Levy: Understanding the IRS’s Most Dangerous Levy Action

In certain instances, the IRS can issue a jeopardy levy to seize available assets without the taxpay...

January 31, 2013Ben WagnerCategories: Collection IssuesTags: ability to pay, compromise application, decrease in income, excess monthly income, installment agreement, Internal Revenue Manual, Internal Revenue Manual 5.15.1.6, Internal Revenue Service, IRM 5.15.1.6, IRS', MDR, Minnesota Department of Revenue, Offer in Compromise, payment agreement, payment plan, reasonable alternative to enforced collection action

Calculating Excess Income – Dealing with Significant Changes in Income

A key factor for most taxpayers negotiating a payment plan or a compromise with either the Internal ...

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