The Internal Revenue Service (IRS), like any self-respecting bureaucracy, sometimes makes mistakes. When those mistakes occurs, a taxpayer can make a “qualified offer,” which might lead to a settlement and obviate the need for a drawn out court battle. If the case nevertheless goes to Tax Court, and the taxpayer prevails in their case, they [...]
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, [...]
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 [...]
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 [...]
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 fight over who meets the definition of a “real estate professional” is not a new one. Fortunately, the taxpayer’s burden for satisfying that definition has only been eased by the expansion of digital tools available for tracking time. That being said, the United States Tax Court’s (Court’s) memorandum opinion in Hairston v. Comm’r of [...]
Substantiating business expenses is a common problem for many businesses going through an audit with either the Internal Revenue Service (IRS) or the Minnesota Department of Revenue (MDR). In previous blog articles, we addressed the four steps (step 1, step 2, step 3, step 4) to substantiating most business expenses. This article will focus on [...]
Substantiating business expenses is a common problem for businesses going through an audit with either the Internal Revenue Service (IRS) or the Minnesota Department of Revenue (MDR). In previous blog articles, we addressed the first, second, and third steps of a four step process in an IRS or MDR substantiation audit. This article will [...]
Substantiating business expenses is a common problem for many businesses going through an audit with either the Internal Revenue Service (IRS) or the Minnesota Department of Revenue (MDR). In previous blog articles, we addressed the first and second steps of a four step process in an IRS or MDR substantiation audit. This article will focus [...]