Audits – Wagner Tax Law

September 17, 2024Ben WagnerCategories: Audits, Ben Wagner, Internal Revenue ServiceTags: Audit, CA tax lawyer, California tax lawyer, Corporate Jet Audit, DOR attorney, DOR lawyer, DOR tax attorney, DOR tax case, Entertainment Deduction, Entertainment Disallowance, Inflation Reduction Act, 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, sd tax lawyer, st. paul tax, st. paul tax attorney, st. paul tax lawyer, tax attorney, tax attorney mn, tax lawyer mn, twin cities attorney tax, twin cities tax, Twin Cities Tax Attorney, Twin Cities Tax Lawyer, wi tax lawyer, wisconsin tax attorney

Internal Revenue Service Plans Dozens of Corporate Jet Audits

On February 21, 2024, the Internal Revenue Service (IRS) announced that it plans to begin dozens of ...

June 26, 2024Ben WagnerCategories: Audits, Ben Wagner, Charitable Contributions, U.S. Tax CourtTags: Art Donations, Audit, CA tax lawyer, California tax lawyer, Charitable Deductions, Charitable Donations, Conservation easement, Deductions, DOR attorney, DOR lawyer, DOR tax attorney, DOR tax case, Economic Substance, 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, sd tax lawyer, st. paul tax, st. paul tax attorney, st. paul tax lawyer, tax attorney, tax attorney mn, Tax Court, tax lawyer mn, twin cities attorney tax, twin cities tax, Twin Cities Tax Attorney, Twin Cities Tax Lawyer, US Tax Court, wi tax lawyer, wisconsin tax attorney

The Challenges for Art Donation (Part 2 of 3): Economic Substance

As discussed in part one of this series on art donations, a taxpayer who wishes to receive a tax ded...

March 6, 2022Ben WagnerCategories: Audits, Ben Wagner, UncategorizedTags: business IRS audit, how long does the IRS have to assess taxes, IRS attorney minneapolis, IRS attorney twin cities, irs examination, irs hobby case, irs twin cities attorney, Minneapolis IRS Tax Audit, Minneapolis Tax Attorney, Minneapolis Tax Firm, Minneapolis Tax Lawyer, minnesota examination, profit motive, profit motive case irs, st. paul tax lawyer, tax attorney saint paul, Twin Cities Attorney Taxes

A Sordid Tale of Donkeys and Horses: Tax Court Style – Part Two

On December 16, 2021, the United States Tax Court issued a memorandum opinion in the case of Skolnic...

June 7, 2020Ben WagnerCategories: Audits, Ben Wagner, U.S. Tax CourtTags: california tax attorney, California tax lawyer, iowa tax attorney, iowa tax lawyer, Metro Minnesota Tax Attorney, Metro MN Tax Attorney, Metro MN Tax Lawyer, minneapolis tax, Minneapolis Tax Attorney, Minneapolis Tax Firm, Minneapolis Tax Lawyer, Minnesota IRS Audit, minnesota tax, Minnesota Tax Attorney, Minnesota Tax Firm, Minnesota Tax Lawyer, MN Tax Attorney, saint, tax attorney, tax attorney minneapolis, tax attorney mn, tax attorney saint paul, tax lawyer mn, tax lawyer saint paul, wagner law firm, Wagner Tax LAw, wisconsin irs issues, wisconsin tax attorney, wisconsin tax lawyer

Not Exactly Bona Fide: Avoiding The Faulty Loan Trap

It is not uncommon for small businesses to rely on friends and family for loans to assist the busine...

October 28, 2019Ben WagnerCategories: Audits, Ben Wagner, U.S. Tax CourtTags: chicago tax attorney, chicago tax lawyer, iowa tax attorney, iowa tax lawyer, irs audit tax attorney, irs examination, material participation audit, material participation irs, material participation minnesota, midwest tax attorney, minneapolis tax, Minneapolis Tax Attorney, Minneapolis Tax Lawyer, minnesota examination, Minnesota Tax Attorney, Minnesota Tax Lawyer, north dakota tax attorney, south dakota tax attorney, tax attorney saint paul, tax lawyer saint paul, twin cities tax, Twin Cities Tax Attorney, Twin Cities Tax Lawyer, wisconsin tax attorney, wisconsin tax lawyer

Can You Remotely Satisfy The Material Participation Test?

For many taxpayers with multiple active business interests, the material participation test can be a...

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...

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...

July 24, 2018Ben WagnerCategories: Audits, Ben WagnerTags: california tax attorney, colorado marijuana irs, colorado tax attorney, getting information from the IRS, Internal Revenue Service, irs audit marijuana, irs california audit, irs examination marijuana, marijuana california irs, marijuana irs, Metro MN Tax Lawyer, Minneapolis Tax Attorney, Minneapolis Tax Lawyer, 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

Marijuana Dispensaries and the Federal Tax Trap

The marijuana industry has experienced a nationwide boom in the last five years. In 2013, the mariju...

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...

March 14, 2017Guest Contributor – Thomas M. ReganCategories: Accounting, Audits, Collection Issues, Tom Regan, U.S. Tax CourtTags: burden of proving payment, CDP, How long do I keep my tax records, pattern of paying, Paynter

How Long Do I Need To Keep My Tax Records?

I am often asked how long do I have to maintain records to protect myself against actions by the Int...

June 23, 2016Guest Contributor – Thomas M. ReganCategories: Accounting, Audits, Collection Issues, Employment Taxes, Tom ReganTags: decline inRrevenue Officers, early aleerts for Federal tax deposits, early alerts for FTD, EFTPS, employment taxes, problems with payroll tax preparers, real-time information, Tax Gap

Employment Taxes and Early Intervention

The IRS appears to be more serious about pursuing and prosecuting companies that do not pay their e...

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...

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