IRS’ – Wagner Tax Law

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...

September 18, 2018Ben WagnerCategories: FBARTags: 2011 OVD Program, 2012 OVD Program, california tax attorney, California tax lawyer, chicago tax attorney, chicago tax lawyer, FBAR, FBAR controversey, FBAR disclosure, FBAR dispute, FBAR program, Foreign Bank Account Reporting, Internal Revenue Service, Internal Revenue Service’s (IRS’s) Offshore Voluntary Disclosure Program (OVD Program), IRS', Isle of Mann Tax Treaty, Metro MN Tax Lawyer, Minneapolis Tax Attorney, Minneapolis Tax Lawyer, minnesota tax, MN Tax Attorney, Offshore Voluntary Disclosure Program (OVD Program), OVD Program, Report of Foreign Bank and Financial Account, Report of Foreign Bank and Financial Account (FBAR), san francisco tax lawyer, sanfrancisco tax attorney, st. paul tax, st. paul tax attorney, st. paul tax lawyer, States of Guernsey Tax Treaty, States of Jersey Tax Treaty, tax attorney mn, tax lawyer mn, twin cities tax, Twin Cities Tax Attorney, Twin Cities Tax Lawyer, wi tax attorney, wisconsin tax attorney

The IRS’s Expanding Definition Of Willfulness In FBAR Cases

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

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...

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 6, 2017Kathleen (Splett) PfutzenreuterCategories: Installment Agreements, Kathleen (Splett) PfutzenreuterTags: additional time to pay taxes, Audit, cannot pay taxes, default, defaulted installment agreement, defaulted payment plan, defaulted payment plan IRS, FBAR controversey, installment agreement, installment agreement IRS, Internal Revenue Service, IRS', Metro MN Tax Lawyer, Minneapolis Tax Attorney, Minneapolis Tax Lawyer, MN Tax Attorney, pay the IRS over time, payment options IRS, payment plan, payment plan IRS, Twin Cities Tax Attorney, Twin Cities Tax Lawyer

Reinstating Defaulted IRS Installment Agreements

Defaulted Installment Agreements The IRS expects taxpayers to pay all of their tax liabilities in fu...

February 9, 2014Guest Contributor – Thomas M. ReganCategories: Collection Issues, Collection Options, Installment Agreements, Offer In CompromiseTags: Bankruptcy, currently not collectible, Innocent Spouse, installment agreement, IRS', Offer in Compromise, options, owe, payment plan, streamlined, taxes

I Owe the IRS Money – What Can I Do?

We often receive telephone calls and e-mails from individuals and businesses who have been contacted...

February 22, 2013Ben WagnerCategories: LevyTags: 6331, 7429, CDP Hearing, Collection Due Process Hearing, Collection Due Process or Equivalent Hearing., Internal Revenue Service jeopardy levy, IRC 6331, IRC 7429, IRS Appeals Office, IRS jeopardy assessment, IRS jeopardy levy, IRS', Jeopardy assessment, jeopardy levy, no notice levy

The Jeopardy Levy: Understanding the IRS’s Most Dangerous Levy Action

In certain instances, the IRS can issue a jeopardy levy to seize available assets without the taxpay...

January 31, 2013Ben WagnerCategories: Collection IssuesTags: ability to pay, compromise application, decrease in income, excess monthly income, installment agreement, Internal Revenue Manual, Internal Revenue Manual 5.15.1.6, Internal Revenue Service, IRM 5.15.1.6, IRS', MDR, Minnesota Department of Revenue, Offer in Compromise, payment agreement, payment plan, reasonable alternative to enforced collection action

Calculating Excess Income – Dealing with Significant Changes in Income

A key factor for most taxpayers negotiating a payment plan or a compromise with either the Internal ...

January 10, 2013Ben WagnerCategories: Claim For RefundTags: 259 (1935), 295 U.S. 247, 417 F.3d 1375 (Fed. Ct. Claims 2005), 52 S.Ct. 145 (1932), amended returns, Bull v. United States, Chief Counsel Advice (CCA) 201252015, CI Division, claim for refund, Criminal Investigations Division, Internal Revenue Service, IRC § 6501(c)(7), IRC 6501, IRC 6501(a), IRS', Lewis v. Reynolds, Pacific Gas and Elec. Co. and PG & E Corporation v. United States, refund from amended returns, return preparation, Revenue Ruling 85-67, statutory period for assessment, waiting until the last minute

The Potential Problems Taxpayers Face When Waiting Until the Last Minute to Timely File Amended Returns

Waiting until the last minute is nearly always a bad strategy. This is certainly true in tax prepara...

October 2, 2012Ben WagnerCategories: LiensTags: credit repair, Credit Restoration, Fresh Start program, Internal Revenue Service, IRS', lien release, lien withdrawal, MDR, Minnesota Department of Revenue, NFTL, Notice of Federal Tax Lien, state tax lien, tax lien

What Do You Do When the IRS or MDR Does Not Issue A Lien Release?

A tax lien is a mechanism that both the IRS and the MDR use to secure their interest in taxpayers’...

September 11, 2012Ben WagnerCategories: Collection OptionsTags: Application for Certificate of Discharge of Property from Federal Tax Lien, Application for Certificate of Subordination of Federal Tax Lien, Form 14134, Form 14135, Internal Revenue Service, IRS', Refinancing options

Using Your Home’s Equity To Satisfy Your Unpaid Federal Tax Obligations

Lately, we have seen local banks informing taxpayers that if a federal tax lien is filed, the bank c...