The following tale is the first in a two part series relating to a couple of recent decisions from the United States Tax Court. Both decisions center around the often-litigated topic of a taxpayer’s profit-motive and whether those taxpayers should have been the allowed the losses stemming from their breeding businesses. On December 21, 2021, [...]
Appearing in the October of 2021 issue of ALI CLE’s The Practical Lawyer is an article by Kathleen E. (Splett) Pfutzenreuter and Benjamin A. Wagner addressing a variety of tax topics that small and solo firm lawyers should be ready to answer. The tax topics covered include: when to talk to a tax accountant or [...]
The United States Department of Treasury (the Treasury) issued “The American Families Plan Tax Compliance Agenda,” detailing how the current administration intends to tackle the ever-looming noncompliance issue. This report was a follow up to the April of 2021 American Families Plan that included proposals that the administration announced to increase tax compliance. The Treasury [...]
Corporate income taxes are generally the responsibility of the corporation and not the individuals that own the corporation. However, there are circumstances where the Internal Revenue Service (IRS) can pursue an assessment of those obligations against the individuals. One of those methods of assessment is an alter ego and it is pursued when the IRS [...]
The on-going COVID-19 pandemic has had a dramatic impact on the daily operations for the Internal Revenue Service (IRS). The IRS has appeared to have done its level best to provide taxpayers with options for securing vital documentation. Though, taxpayers attempting to obtain a lien release or certificate of discharge have experienced some delays in [...]
The proper classification of workers is a decision that is critical to the success or failure of many small businesses. This is especially true in light of the on-going public health crisis, where margins have been squeezed to their absolute limits. For more information relating to the classification of workers, please see these previous blog [...]
It is not uncommon for small businesses to rely on friends and family for loans to assist the business in meeting operating expenses. This is even more true given the on-going pandemic. Small businesses are scrambling to make sure they can meeting their operating expenses. Unfortunately, many of those small business owners are so focused [...]
People often joke that the only certainties in life are death and taxes. Well, it turns out that, when it comes to the report of Foreign Bank and Financial Account (FBAR) penalties, death may have finally met its match. The Southern District of Florida issued a decision in United States v. Green, 2020 BL 165965 [...]
On April 24, 2020, the Internal Revenue Service (IRS) issued an internal memo advising its employees that it would be recalling those employees involved in “mission critical” operations. This internal memo represents the most significant update to the IRS’s “People First Initiative,” a program intended to respond to the challenges of COVID-19 by providing a [...]
The recently imposed social distancing measures that are critical and essential to our nation’s battle with the coronavirus have had a dramatic impact on everyone’s everyday life. No one is exempt or excused from that impact. This includes our nation’s taxing authorities. The Internal Revenue Service (IRS) has created and is updating a website to [...]