Internal Revenue Service | Wagner Tax Law

What’s in a Name?: The ABA Attempts to Define “Cryptocurrency”

Until relatively recently, the number of individuals who bought and sold cryptocurrencies (crypto) a...

April 23, 2022Ben WagnerCategories: Ben Wagner, U.S. Tax CourtTags: california tax attorney, California tax lawyer, Internal Revenue Service, iowa tax attorney, iowa tax lawyer, IRS attorney minneapolis, IRS attorney twin cities, IRS Audits, IRS tax attorney, irs twin cities attorney, Minneapolis Tax Attorney, Minneapolis Tax Lawyer, Minnesota Tax Attorney, Minnesota Tax Lawyer, north dakota tax attorney, qualified offer irs, south dakota tax attorney, tax attorney saint paul, tax lawyer saint paul, Twin Cities Attorney Taxes, twin cities tax, Twin Cities Tax Attorney, Twin Cities Tax Lawyer, united states federal district court, united states tax court, wisco, wisconsin irs issues, wisconsin tax attorney, wisconsin tax lawyer

A Qualified Offer the IRS Could Refuse

The Internal Revenue Service (IRS), like any self-respecting bureaucracy, sometimes makes mistakes. ...

January 29, 2022Ben WagnerCategories: Ben Wagner, Profit Motive, UncategorizedTags: california tax attorney, California tax lawyer, getting information from the IRS, Internal Revenue Service, iowa tax attorney, iowa tax lawyer, IRS attorney, IRS attorney minneapolis, IRS attorney twin cities, irs audit tax attorney, IRS Audits, irs california audit, IRS collections minnesota, irs examination, irs hobby case, IRS information, IRS tax attorney, irs tax lawyer, irs twin cities attorney, MDR, Metro Minnesota Tax Attorney, Metro MN Tax Attorney, Metro MN Tax Lawyer, minneapolis tax, Minneapolis Tax Attorney, Minneapolis Tax Firm, Minneapolis Tax Lawyer, Minnesota Department of Revenue audits, Minnesota domicile, Minnesota IRS Audit, Minnesota Tax Attorney, Minnesota Tax Lawyer, mn audit settlement, MN Tax Attorney, MN Tax Firm, MN Tax Lawyer, north dakota tax attorney, profit motive, profit motive case irs, profit motive irs, south dakota tax attorney, wisconsin irs issues, wisconsin tax attorney, wisconsin tax lawyer

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

The following tale is the first in a two part series relating to a couple of recent decisions from t...

November 30, 2021Kathleen (Splett) PfutzenreuterCategories: Kathleen (Splett) PfutzenreuterTags: Internal Revenue Service, Metro MN Tax Lawyer, Minneapolis Tax Attorney, Minneapolis Tax Lawyer, minnesota tax, MN Tax Attorney, tax lawyer mn, twin cities tax, Twin Cities Tax Attorney, Twin Cities Tax Lawyer

Three Things – Ask A Tax Attorney

Recently, I wrote an article for the Hennepin County Lawyer addressing some of the kinds of tax ques...

October 4, 2021Ben WagnerCategories: Ben WagnerTags: california tax attorney, California tax lawyer, Internal Revenue Service, iowa tax attorney, iowa tax lawyer, IRS attorney twin cities, IRS tax attorney, irs twin cities attorney, madison tax lawyer, Metro MN Tax Lawyer, Minneapolis Tax Attorney, Minneapolis Tax Lawyer, minnesota tax, Minnesota Tax Attorney, Minnesota Tax Lawyer, MN Tax Attorney, north dakota tax attorney, south dakota tax attorney, st. paul tax, st. paul tax attorney, st. paul tax lawyer, tax attorney mn, tax attorney saint paul, tax lawyer mn, tax lawyer saint paul, twin, Twin Cities Attorney Taxes, twin cities tax, Twin Cities Tax Attorney, Twin Cities Tax Lawyer, wisconsin irs issues, wisconsin tax attorney, wisconsin tax lawyer

Tax Questions Every Solo And Small Firm Lawyer Should Be Able To Answer

Appearing in the October of 2021 issue of ALI CLE’s The Practical Lawyer is an article by Kathleen...

July 28, 2021Kathleen (Splett) PfutzenreuterCategories: LevyTags: american rescue plan act, Internal Revenue Service, IRS guidance, Levy, Metro MN Tax Lawyer, Minneapolis Tax Attorney, Minneapolis Tax Lawyer, minnesota tax, MN Tax Attorney, restaurant levy, restaurant revitalization fund, restaurant tax levy, RRF, small business administration, tax lawyer mn, twin cities tax, Twin Cities Tax Lawyer

IRS Issues Guidance Regarding Levy Actions Involving Restaurant Revitalization Fund

The American Rescue Plan Act established the Restaurant Revitalization Fund (RRF) to provide support...

March 11, 2021Ben WagnerCategories: Ben Wagner, Collection Issues, Federal District CourtTags: alter ego assessment irs, alter ego district court, Internal Revenue Service, irs alter ego, IRS attorney twin cities, IRS collections minnesota, irs seizure, IRS tax attorney, irs twin cities attorney, Minneapolis Tax Attorney, Minneapolis Tax Lawyer, Minnesota IRS Audit, tax attorney mn, tax attorney saint paul, tax lawyer mn, tax lawyer saint paul, Twin Cities Attorney Taxes, twin cities tax, Twin Cities Tax Attorney, Twin Cities Tax Lawyer

IRS Prevails In Pursuing An Alter Ego Assessment

Corporate income taxes are generally the responsibility of the corporation and not the individuals t...

February 15, 2021Kathleen (Splett) PfutzenreuterCategories: Collection Issues, Covid 19Tags: covid 19, covid 19 relief, covid 19 relief individuals, first time penalty abatement, installment agreement, Internal Revenue Service, irs people first initiative, Offer in Compromise, penalty abatement, reasonable cause, streamlined installment agreement

IRS Offers Additional Taxpayer Relief in Response to Covid-19

On March 25, 2020, the Internal Revenue Service (IRS) released guidance related to its “People Fir...

July 6, 2020Ben WagnerCategories: Ben Wagner, Independent ContractorsTags: cal, california tax attorney, California tax lawyer, Internal Revenue Manual, Internal Revenue Service, iowa tax attorney, iowa tax lawyer, IRS attorney, IRS attorney minneapolis, IRS attorney twin cities, IRS Audits, irs california audit, irs employment examination, irs examination, irs independent contractor, IRS information, IRS tax attorney, irs tax lawyer, mdr worker classification examination, 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, tax attorney saint paul, tax lawyer mn, tax lawyer saint paul, Twin Cities Tax Attorney, Twin Cities Tax Lawyer, wagner law firm, Wagner Tax LAw, wisconsin irs issues, wisconsin tax attorney, wisconsin tax lawyer, worker classification examination, worker classification examination irs, worker classification examination mdr

Can Cleaners Be Treated As Independent Contractors?

The proper classification of workers is a decision that is critical to the success or failure of man...

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...

May 6, 2019Ben WagnerCategories: Ben Wagner, Claim For Refund, PenaltiesTags: abatement, california tax attorney, California tax lawyer, estimated tax penalty, Internal Revenue Service, IRS estimates, IRS information, IRS obligations, IRS penalty abatement, IRS', madison tax attorney, madison tax lawyer, milwaulkee tax attorney, milwaulkee tax lawyer, Minneapolis Tax Lawyer, penalty, penalty relief irs, tax attorney minneapolis, tax attorney mn, tax attorney saint paul, tax lawyer irs, tax lawyer mn, tax lawyer penalties, tax lawyer saint paul, Twin Cities Tax Attorney, Twin Cities Tax Lawyer, wisconsin tax attorney

Taking Advantage Of Expanded Penalty Relief

The recent enactment of the Tax Cut and Jobs Act (TCJA) put many individual taxpayers in a difficult...

February 20, 2019Ben WagnerCategories: Ben Wagner, Settlements and VerdictsTags: Benjamin Wagner, CA tax lawyer, chicago tax att, chicago tax lawyer, getting information from the IRS, Internal Revenue Service, irs audit settlement, irs settlement physical injury, IRS settlement tax, Kathleen Splett, madison tax lawyer, Metro MN Tax Lawyer, milwaulkee tax attorney, Minneapolis Tax Attorney, Minneapolis Tax Lawyer, minnesota tax, mn audit settlement, MN Tax Attorney, settlement physical injury, st. paul tax, st. paul tax attorney, st. paul tax lawyer, tax attorney jeopardy levy, tax attorney jeopardy levyu, tax attorney mn, tax lawyer jeopardy levy, tax lawyer mn, Twin Cities Attorney Taxes, twin cities tax, Twin Cities Tax Attorney, Twin Cities Tax Lawyer, Wagner Tax LAw, wisconsin tax attorney

Emphasizing Physical Injuries In Settlement Agreements

The United States Tax Court (Court) recently issued a decision highlighting, yet again, the importan...

January 2, 2019Ben WagnerCategories: Ben Wagner, Marijuana & Tax, U.S. Tax CourtTags: california tax attorney, California tax lawyer, cogs irs weed, colorado irs audit, colorado irs tax, colorado marijuana irs, colorado tax attorney, colorado tax lawyer, Internal Revenue Service, irs 280e, IRS attorney twin cities, irs audit marijuana, irs california audit, irs examination marijuana, irs irc 280e, irs marijuana, irs weed, marijuana california irs, marijuana cogs irs, marijuana irs, Metro Minnesota Tax Attorney, minneapolis tax, Minneapolis Tax Attorney, Minnesota IRS Audit, minnesota tax, Minnesota Tax Attorney, Minnesota Tax Lawyer, Twin Cities Tax Attorney, Twin Cities Tax Lawyer

Another Tax Blow To The Marijuana Industry

The marijuana industry remains in a difficult position when it comes to the federal tax implications...

October 22, 2018Ben WagnerCategories: Ben Wagner, Collection Options, LevyTags: Benjamin Wagner, CA tax lawyer, chicago tax att, chicago tax lawyer, getting information from the IRS, Internal Revenue Service, Internal Revenue Service jeopardy levy, internal revenue service levy, IRS jeopardy assessment, IRS jeopardy levy, irs levy, jeopardy levy, Kathleen Splett, madison tax lawyer, Metro MN Tax Lawyer, milwaulkee tax attorney, Minneapolis Tax Attorney, Minneapolis Tax Lawyer, minnesota tax, MN Tax Attorney, Offer in Compromise, st. paul tax, st. paul tax attorney, st. paul tax lawyer, tax attorney jeopardy levy, tax attorney jeopardy levyu, tax attorney mn, tax lawyer jeopardy levy, tax lawyer mn, twin cities tax, Twin Cities Tax Attorney, Twin Cities Tax Lawyer, Wagner Tax LAw, wisconsin tax attorney

Can The IRS Really Seize My Assets Without Telling Me First?

The Internal Revenue Service (IRS) can utilize its jeopardy levy function (i.e., taking a taxpayer�...

October 3, 2018Kathleen (Splett) PfutzenreuterCategories: Collection Issues, Collection Options, Installment Agreements, Kathleen (Splett) Pfutzenreuter, Levy, Offer In CompromiseTags: Benjamin Wagner, employee tax issues, employee tax levy, employee tax levy exemption, employer tax issues, employer tax levy, installment agreement, Internal Revenue Service, irs collection tools, irs levy, Kathleen Splett, levy exemption, Metro MN Tax Lawyer, Minneapolis Tax Attorney, Minneapolis Tax Lawyer, minnesota tax, MN Tax Attorney, Offer in Compromise, resolution of irs debt, st. paul tax, st. paul tax attorney, st. paul tax lawyer, tax levy, twin cities tax, Twin Cities Tax Attorney, wage levy

How Does an Employer Comply with an IRS Wage Levy?

When an individual has outstanding federal tax liabilities, the Internal Revenue Service (IRS) has a...

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The IRS’s Expanding Definition Of Willfulness In FBAR Cases

The Internal Revenue Service’s (IRS’s) Offshore Voluntary Disclosure Program (Program) has eleme...

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 12, 2018Ben WagnerCategories: Ben Wagner, Profit Motive, U.S. Tax CourtTags: getting information from the IRS, Internal Revenue Service, irs business deductions, irs business tax case, irs hobby case, irs substantiation case, Metro MN Tax Lawyer, profit motive case irs, profit motive irs, 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

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 18, 2018Kathleen (Splett) PfutzenreuterCategories: Collection Issues, Kathleen (Splett) Pfutzenreuter, PenaltiesTags: dispute irs penalties, getting information from the IRS, Internal Revenue Service, irs dispute, irs disputew, irs fight, IRS Penalties, irs taxes, late filing irs, Metro MN Tax Lawyer, Minneapolis Tax Attorney, minnesota tax, MN Tax Attorney, Offer in Compromise, penalty relief irs, resolve irs taxes, st. paul tax, st. paul tax attorney, tax attorney mn, tax lawyer mn, twin cities tax, Twin Cities Tax Attorney, Twin Cities Tax Lawyer

I missed the deadline to file my tax return. Now what?

I missed the deadline to file my tax return. Now what? The deadline for individual taxpayers to file...

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