Appeals – Wagner Tax Law

December 21, 2023Ben WagnerCategories: Appeals, Bankruptcy, Ben Wagner, Internal Revenue Service, PenaltiesTags: Appeals Court, application fees, Bankruptcy, Bankruptcy Court, CA tax lawyer, California tax lawyer, district court, DOR attorney, DOR lawyer, DOR tax attorney, DOR tax case, Fifth Circuit Court of Appeals, Internal Revenue Service, IRS, lawyer tax twin cities, MDR, MDR information, Metro MN Tax Lawyer, minneapolis tax, Minneapolis Tax Attorney, Minneapolis Tax Lawyer, minnesota tax, MN Tax Attorney, penalty, prevailing party, sd tax lawyer, st. paul tax, st. paul tax attorney, st. paul tax lawyer, tax attorney, tax attorney mn, tax lawyer mn, tax shelter, tax shelter organization, twin cities attorney tax, twin cities tax, Twin Cities Tax Attorney, Twin Cities Tax Lawyer, wi tax lawyer, wisconsin tax attorney

When Winning Isn’t “Prevailing”: Success in Bankruptcy Court Does Not Translate to Attorneys’ Fees

In June 2016, William Canada, Jr. took the Internal Revenue Service (IRS) to bankruptcy court and wo...

March 9, 2020Kathleen (Splett) PfutzenreuterCategories: Appeals, Claim For Refund, Collection Issues, Collection Options, Employment Taxes, Kathleen (Splett) Pfutzenreuter, Levy, Liens, Offer In Compromise, Penalties, Trust Fund Recovery PenaltyTags: doubt as to liability, employment taxes, fica taxes, Internal Revenue Service, personal assessment, TFRP, Trust Fund Recovery Penalty, withholding taxes

How to Appeal the Trust Fund Recovery Penalty After the Appeal Period has Passed: Offer in Compromise, Doubt as to Liability

There are many reasons businesses fall behind on paying their federal tax liabilities. Falling behin...

October 1, 2019Kathleen (Splett) PfutzenreuterCategories: Accounting, Appeals, Audits, Claim For Refund, Collection Issues, Collection Options, Installment Agreements, Kathleen (Splett) Pfutzenreuter, Levy, Liens, Offer In Compromise, Penalties, U.S. Court of Federal Claims, U.S. Tax Court, UncategorizedTags: Audit, collection, federal tax attorney, federal tax lawyer, how to understand a letter from the irs, how to understand irs process, IRS appeal, irs appeals, IRS audit, IRS collections, IRS court, IRS litigation, irs tax road map, Minnesota Tax Attorney, Minnesota Tax Lawyer, united states tax court

IRS Taxpayer Roadmap

The Internal Revenue Service (IRS) Taxpayer Advocate Service (TAS) recently released the above “su...

June 19, 2019Kathleen (Splett) PfutzenreuterCategories: Accounting, Appeals, Ben Wagner, Claim For Refund, Kathleen (Splett) Pfutzenreuter, PenaltiesTags: federal tax attorney, federal tax lawyer, IRS penalty, late filing tax return, late filling penalty, late tax return, Minnesota Tax Attorney, Minnesota Tax Lawyer, penalty abatement

IRS Announces Increase to Late Filing Penalties for 2018 Federal Tax Returns

The IRS recently announced that taxpayers who owe tax and did not file their 2018 returns before Fri...

January 24, 2019Kathleen (Splett) PfutzenreuterCategories: Appeals, Collection Issues, Collection Options, Federal District Court, Internal Revenue Service, Kathleen (Splett) Pfutzenreuter, Levy, LiensTags: department of justice foreclosure, district of minnesota, doj foreclosure, enforced collection action, federal tax attorney, federal tax lawyer, irs foreclosure, lax lien, minnesota tax, Minnesota Tax Attorney, Minnesota Tax Lawyer, tax levy, united states federal district court

Can the IRS Can Foreclose on My Home?

Yes. If you owe money to the Internal Revenue Service (IRS), the IRS has many tools it may use to co...

August 6, 2018Kathleen (Splett) PfutzenreuterCategories: Accounting, Appeals, Audits, Collection Issues, Employment Taxes, Income and Deductions, Kathleen (Splett) Pfutzenreuter, Real Estate, Sales & Use Tax AuditsTags: employee benefits, moving expenses, tax cuts and jobs act, TCJA

Are Moving Expenses Tax Free Under the New Tax Law?

Starting January 1, 2018, through December 31, 2025, job-related moving expenses are no longer tax-f...

June 24, 2018Kathleen (Splett) PfutzenreuterCategories: Appeals, Audits, Bankruptcy, Collection Issues, Employment Taxes, Income and Deductions, Kathleen (Splett) Pfutzenreuter, Levy, U.S. Tax CourtTags: sexual harassment attorney fees, sexual harassment business tax expense, sexual harassment nondisclosure agreement, sexual harassment settlement, sexual harassment settlement tax consequences, sexual harassment tax, sexual harassment tax liability business, workplace sexual abuse, workplace sexual harassment

Are Sexual Harassment Settlement Payments and Attorney Fees Tax Deductible?

Are Sexual Harassment Settlement Payments and Attorney Fees Tax Deductible? It depends on whether th...

April 3, 2018Kathleen (Splett) PfutzenreuterCategories: Accounting, Appeals, Audits, Ben Wagner, Collection Issues, Collection Options, FBAR, Kathleen (Splett) Pfutzenreuter, Levy, Offshore Voluntary Disclosure Program, Penalties, UncategorizedTags: 2011 OVD Program, 2012 OVD Program, civil penalties offshore voluntary disclosure program, civil penalties OVDP, criminal penalties internal revenue service, criminal penalties IRS, criminal penalties offshore voluntary disclosure program, criminal penalties OVDP, end date OVDP, FBAR, FBAR controversey, FBAR disclosure, FBAR dispute, FBAR penalties, FBAR program, federal tax, federal tax attorney, federal tax lawyer, foreign assets, Foreign Bank Account Reporting, foreign bank accounts, increase FBAR, inflation FBAR, Internal Revenue Service, IRS attorney, irs lawyer, IRS tax attorney, irs tax lawyer, IRS', Metro MN Tax Lawyer, Minneapolis Tax Attorney, Minneapolis Tax Lawyer, minnesota tax, MN Tax Attorney, offshore volunary disclosure, offshore voluntary disclosure program ends, OVDP, penalties assets abroad, penalties foreign assets, penalties foreign bank accounts, penalties money abroad, requirements for offshore voluntary disclosure, requirements for OVDP, st. paul tax, st. paul tax attorney, tax attorney, Twin Cities Tax Attorney

Recent Announcements: The IRS to End Offshore Voluntary Disclosure Program on September 28, 2018; FinCEN Increases FBAR Penalties to Reflect Inflation

Offshore Voluntary Disclosure Program Ends September 28, 2018 The IRS recently announced that it wil...

March 13, 2018Kathleen (Splett) PfutzenreuterCategories: Accounting, Appeals, Audits, Income and Deductions, Kathleen (Splett) Pfutzenreuter, Minnesota Tax Court, Sales & Use Tax Audits, Settlements and VerdictsTags: administrative appeals DOR, administrative appeals minnesota, administrative appeals state, administrative appeals state of minnesota, appeals DOR, appeals minnesota, appeals state, appeals state of minnesota, time to appeal, time to dispute tax liability

Deadline to Appeal Minnesota Department of Revenue Assessment of Additional Tax

The Minnesota Department of Revenue (MDR) generally has 3.5 years from the date a tax return was due...

February 15, 2018Kathleen (Splett) PfutzenreuterCategories: Accounting, Appeals, Audits, Collection Issues, Collection Options, Installment Agreements, Kathleen (Splett) Pfutzenreuter, Liens, UncategorizedTags: installment agreement test criteria, Internal Revenue Service, IRS', long term payment plan, new streamlined installment agreement, payment plan, streamlined installment agreements

IRS Tests Expanded Streamlined Installment Agreement Program

New IRS Test Criteria for Streamlined Installment Agreements: Liabilities Up to $100,000 Eligible fo...

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...

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...

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...

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...

November 27, 2012Guest Contributor – Thomas M. ReganCategories: Accounting, Appeals, Audits, Employment Taxes, Independent ContractorsTags: Independent contractor, Section 530

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...

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

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

Taxpayers and representatives often ask us: how long does the IRS have to make changes to an individ...

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