Guest Contributor – Mike O’Brien

April 23, 2014Guest Contributor – Mike O'BrienCategories: Appeals, Audits, Minnesota Tax Court, ResidencyTags: 183 day rule, 183 days, 26 factors, abode, abode and more than 1/2 time, abode definition, abode definition in Minnesota, abode in Minnesota, abode in Minnesota and half time, am I a Minnesota resident?, am I a resident of Minnesota, change Minnesota domicile, change Minnesota residency, changing Minnesota residency, changing MN residency, days spent in Minnesota, days spent in Minnesota for residency, definition of abode, domicile, Minnesota abode, Minnesota domicile, Minnesota law abode, Minnesota non-domiciliary resident, Minnesota residency law, Minnesota residency presumptions, Minnesota resident, Minnesota resident 183-day rule, Minnesota resident abode, Minnesota resident tax, MN domicile, MN resident, MN resident tax, nondomiciliary Minnesota, presumptions Minnesota resident, residency in Minnesota, resident of Minnesota, tax rules Minnesota resident, tax rules MN resident, twenty-six factors

Who Qualifies as a Resident of Minnesota?: Calculating Time Spent in Minnesota

This is the sixth article in a series dedicated to the rules regarding who qualifies as a “res...

April 5, 2014Guest Contributor – Mike O'BrienCategories: Appeals, Audits, ResidencyTags: 183 day rule, 183 days, 26 factors, abode, abode and more than 1/2 time, abode definition, abode definition in Minnesota, abode in Minnesota, abode in Minnesota and half time, am I a resident of Minnesota, change Minnesota domicile, change Minnesota residency, changing Minnesota residency, changing MN residency, definition of abode, domicile, Minnesota abode, Minnesota domicile, Minnesota law abode, Minnesota non-domiciliary resident, Minnesota residency law, Minnesota residency presumptions, Minnesota resident, Minnesota resident 183-day rule, Minnesota resident abode, Minnesota resident tax, MN domicile, MN resident, MN resident tax, nondomiciliary Minnesota, presumptions Minnesota resident, residency in Minnesota, resident of Minnesota, tax rules Minnesota resident, tax rules MN resident, twenty-six factors

Who Qualifies as a Resident of Minnesota? The Definition of "Abode" in Minnesota

This is the fifth article in a series dedicated to the rules regarding who qualifies as a “res...

March 11, 2014Guest Contributor – Mike O'BrienCategories: Appeals, Audits, ResidencyTags: 183 day rule, 183 days, 26 factors, abode and more than 1/2 time, abode in Minnesota and half time, am I a resident of Minnesota, change Minnesota domicile, change Minnesota residency, changing Minnesota residency, changing MN residency, domicile, Minnesota domicile, Minnesota non-domiciliary resident, Minnesota residency law, Minnesota residency presumptions, Minnesota resident, Minnesota resident 183-day rule, Minnesota resident tax, MN domicile, MN resident, MN resident tax, nondomiciliary Minnesota, presumptions Minnesota resident, residency in Minnesota, resident of Minnesota, tax rules Minnesota resident, tax rules MN resident, twenty-six factors

Who Qualifies as a Resident of Minnesota?: Non-Domiciliary Resident Rules

This is the fourth article in a series dedicated to the rules regarding who qualifies as a “re...

February 19, 2014Guest Contributor – Mike O'BrienCategories: Audits, Minnesota Tax Court, ResidencyTags: 26 factors, change Minnesota domicile, change Minnesota residency, changing Minnesota residency, changing MN residency, domicile, Minnesota domicile, Minnesota residency law, Minnesota residency presumptions, Minnesota resident, Minnesota resident tax, MN domicile, MN resident, MN resident tax, presumptions Minnesota resident, residency in Minnesota, resident of Minnesota, tax rules Minnesota resident, tax rules MN resident, twenty-six factors

Who Qualifies as a Resident of Minnesota?: The Factors Considered to Determine Domicile

This is the third article in a series dedicated to the rules regarding who qualifies as a “res...

January 30, 2014Guest Contributor – Mike O'BrienCategories: ResidencyTags: change Minnesota domicile, change Minnesota residency, changing Minnesota residency, changing MN residency, domicile, Minnesota domicile, Minnesota residency law, Minnesota residency presumptions, Minnesota resident, Minnesota resident tax, MN domicile, MN resident, MN resident tax, presumptions Minnesota resident, residency in Minnesota, resident of Minnesota, tax rules Minnesota resident, tax rules MN resident

Who Qualifies as a Resident of Minnesota?: Presumptions in Minnesota Law

This is the second article in a series dedicated to the rules regarding who qualifies as a “re...

November 4, 2013Guest Contributor – Mike O'BrienCategories: Appeals, Audits, Minnesota Tax Court, ResidencyTags: changing Minnesota residency, changing MN residency, domicile, Minnesota domicile, Minnesota resident, Minnesota resident tax, MN domicile, MN resident, MN resident tax, residency in Minnesota, resident of Minnesota, tax rules Minnesota resident, tax rules MN resident

Who Qualifies as a Resident of Minnesota?: Domiciliary Resident Status

This is the first article in a series dedicated to the rules regarding who qualifies as a “res...

September 18, 2013Guest Contributor – Mike O'BrienCategories: Collection Options, Innocent Spouse ReliefTags: Form 8857, innocent spouse proposed regulations, Innocent Spouse Relief, innocent spouse statute of limitations, irc section 6015, irc section 6015(f), refund innocent spouse relief, Request for Innocent Spouse Relief

IRS Finalizes Procedures for Equitable Relief Under IRC Section 6015

On September 16, 2013, the IRS issued Revenue Procedure 2013-34, which establishes new rules for eva...

August 26, 2013Guest Contributor – Mike O'BrienCategories: Claim For Refund, Collection Options, Innocent Spouse ReliefTags: Form 8857, innocent spouse proposed regulations, Innocent Spouse Relief, innocent spouse statute of limitations, irc section 6015, irc section 6015(f), refund innocent spouse relief, Request for Innocent Spouse Relief

IRS Clarifies Innocent Spouse Statute of Limitations

In a previous blog article, we addressed the courts invalidating the Internal Revenue Service’s (I...

April 25, 2013Guest Contributor – Mike O'BrienCategories: Recovering Legal FeesTags: Internal Revenue Service legal fees paid, IRC 7430, IRC Section 7430, net worth, prevailing party, recovering legal fees, recovering legal fees IRS, recovering litigation costs IRS, substantially justified

Recovering Fees from the Internal Revenue Service – “Prevailing Party” Requirement

This is the second article in a series of articles regarding recovering administrative costs and leg...

April 4, 2013Guest Contributor – Mike O'BrienCategories: Recovering Legal FeesTags: Internal Revenue Service legal fees paid, IRC 7430, IRC Section 7430, net worth, prevailing party, recovering legal fees, recovering legal fees IRS, recovering litigation costs IRS, substantially justified

Recovering Fees from the Internal Revenue Service – Basic Requirements

This is the first article in a series dedicated to recovering administrative costs and legal fees fr...

February 25, 2013Guest Contributor – Mike O'BrienCategories: Accounting, Audits, Income and DeductionsTags: Audit, audit proving business expenses, business audit, business IRS audit, business vehicle deduction, Code Section 162, Code Section 274, continuity and regularity, credit card receipts to prove business expenses, deducting mileage, Documentation, expenses for carrying on a trade or business, gifts deductible, gifts deduction, gifts rules for deducting, income tax audit, IRC Section 162, IRC Section 274, IRS Audits, irs business vehicle, irs meals and entertainment, irs vehicle expenses, listed property irs, meals and entertainment deduction, meals and entertainment expenses, meals and entertainment tax, mileage log taxes, Minnesota audit, Minnesota Department of Revenue audits, necessary business expenses, ordinary and necessary business expenses, ordinary business expenses, profit motive, proving business expenses, receipts to prove business expenses, Section 274, substantiation, trade or business expenses

Substantiating Business Expenses in Audits – Special Rules for Travel, Meals and Entertainment, Gifts, and any “Listed” Property Expenses

Substantiating business expenses is a common problem for many businesses going through an audit with...

February 7, 2013Guest Contributor – Mike O'BrienCategories: Accounting, Audits, Income and DeductionsTags: Audit, audit proving business expenses, business audit, business IRS audit, Code Section 162, continuity and regularity, credit card receipts to prove business expenses, Documentation, expenses for carrying on a trade or business, income tax audit, IRC Section 162, IRS Audits, Minnesota audit, Minnesota Department of Revenue audits, necessary business expenses, ordinary and necessary business expenses, ordinary business expenses, profit motive, proving business expenses, receipts to prove business expenses, substantiation, trade or business expenses

Substantiating Business Expenses in Audits – Step Four: Proving a Business Expense is “Necessary”

Substantiating business expenses is a common problem for businesses going through an audit wi...

January 18, 2013Guest Contributor – Mike O'BrienCategories: Accounting, Appeals, Audits, Income and DeductionsTags: Audit, audit proving business expenses, business audit, business IRS audit, Code Section 162, continuity and regularity, credit card receipts to prove business expenses, Documentation, expenses for carrying on a trade or business, income tax audit, IRC Section 162, IRS Audits, Minnesota audit, Minnesota Department of Revenue audits, necessary business expenses, ordinary and necessary business expenses, ordinary business expenses, profit motive, proving business expenses, receipts to prove business expenses, substantiation, trade or business expenses

Substantiating Business Expenses in Audits – Step Three: Proving a Business Expense is “Ordinary”

Substantiating business expenses is a common problem for many businesses going through an audit with...

December 18, 2012Guest Contributor – Mike O'BrienCategories: Accounting, Audits, Income and Deductions, Profit MotiveTags: Audit, audit proving business expenses, business audit, business IRS audit, Code Section 162, continuity and regularity, credit card receipts to prove business expenses, Documentation, expenses for carrying on a trade or business, income tax audit, IRC Section 162, IRS Audits, Minnesota audit, Minnesota Department of Revenue audits, necessary business expenses, ordinary business expenses, profit motive, proving business expenses, receipts to prove business expenses, substantiation, trade or business expenses

Substantiating Business Expenses in Audits – Step Two: Proving a “Trade or Business” Incurred the Business Expenses

Substantiating business expenses is a common problem for many businesses going through an audit with...

November 20, 2012Guest Contributor – Mike O'BrienCategories: U.S. Tax CourtTags: Filing a Petition in US Tax Court, Tax Court filing documents, Tax Court service, Tax Court serving documents, U.S. Tax Court e-file, U.S. Tax Court electronic filing, U.S. Tax Court filing rules, United States Tax Court e-file, United States Tax Court electronic filing, United States Tax Court filing rules, US Tax Court e-file, US Tax Court electronic filing, US Tax Court filing rules

Filing and Serving Documents in United States Tax Court Proceedings

Federal and state courts continue to evolve as technology evolves. The United States Tax Court is no...

October 31, 2012Guest Contributor – Mike O'BrienCategories: Collection Issues, Family Court, Innocent Spouse ReliefTags: divorce joint tax, eliminate joint tax debt, eliminate joint tax liability, Form 8857, husband and wife tax debt, husband and wife tax liability, husband and wife tax obligation, Innocent Spouse Relief, IRS joint tax obligation, joint tax obligations, relief from joint tax obligations, relief married filing jointly tax obligation, Request for Innocent Spouse Relief

Frequently Asked Tax Questions in Family Law Cases – Allocating Joint Tax Obligations in a Divorce Decree

This is the third post in the Frequently Asked Tax Questions in Family Law Cases series. This series...

October 9, 2012Guest Contributor – Mike O'BrienCategories: Family Court, Income and DeductionsTags: child care expenses tax credit, childcare expenses tax, children tax credit, dependent care tax credit, divorce tax, divorce tax credit, divorce tax issues, IRC Section 152, IRC Section 21, qualifying child tax credit, tax family attorney

Frequently Asked Tax Questions in Family Law Cases – Tax Credit for Child and Dependent Care Expenses

This is the first post in the Frequently Asked Tax Questions in Family Law Cases series. This series...

September 18, 2012Guest Contributor – Mike O'BrienCategories: Accounting, Appeals, Audits, Income and DeductionsTags: how long doe, how long does the IRS have to change a tax return, IRC 6501, IRS statute of limitations, statute of limitations on assessment

Who Qualifies as a Resident of Minnesota?: Calculating Time Spent in Minnesota

Who Qualifies as a Resident of Minnesota? The Definition of "Abode" in Minnesota

Who Qualifies as a Resident of Minnesota?: Non-Domiciliary Resident Rules

Who Qualifies as a Resident of Minnesota?: The Factors Considered to Determine Domicile

Who Qualifies as a Resident of Minnesota?: Presumptions in Minnesota Law

Who Qualifies as a Resident of Minnesota?: Domiciliary Resident Status

IRS Finalizes Procedures for Equitable Relief Under IRC Section 6015

IRS Clarifies Innocent Spouse Statute of Limitations

Recovering Fees from the Internal Revenue Service – “Prevailing Party” Requirement

Recovering Fees from the Internal Revenue Service – Basic Requirements

Substantiating Business Expenses in Audits – Special Rules for Travel, Meals and Entertainment, Gifts, and any “Listed” Property Expenses

Substantiating Business Expenses in Audits – Step Four: Proving a Business Expense is “Necessary”

Substantiating Business Expenses in Audits – Step Three: Proving a Business Expense is “Ordinary”

Substantiating Business Expenses in Audits – Step Two: Proving a “Trade or Business” Incurred the Business Expenses

Filing and Serving Documents in United States Tax Court Proceedings

Frequently Asked Tax Questions in Family Law Cases – Allocating Joint Tax Obligations in a Divorce Decree

Frequently Asked Tax Questions in Family Law Cases – Tax Credit for Child and Dependent Care Expenses

IRS Statute of Limitations on Assessment for Individual Income Taxes: Exceptions and Considerations

IRS Audits: The Administrative Summons and Defending Against the Administrative Summons

Substantiating Business Expenses in Audits – Step One: Providing the Documents