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 [...]
On March 25, 2020, the Internal Revenue Service (IRS) announced its “People First Initiative,” a program intended to respond to the challenges of Covid-19 by providing a variety of relief related to IRS deadlines and collection actions. For additional information, please see our previous blog article regarding the People First Initiative here and the full [...]
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 recently imposed social distancing measures that are critical and essential to our nation’s battle with the coronavirus have had a dramatic impact on everyone’s everyday life. No one is exempt or excused from that impact. This includes our nation’s taxing authorities. The Internal Revenue Service (IRS) has created and is updating a website to [...]
The Internal Revenue Service (IRS) announced, in a recent Information Release and Fact Sheet, that it is going to make more site visits to taxpayers who have delinquent-filed tax returns. Fact Sheet 2020-02 notes that this increased use of compliance strategies is being fueled by the IRS’s increased use of data analytics, research, and other [...]
The recent enactment of the Tax Cut and Jobs Act (TCJA) put many individual taxpayers in a difficult position regarding their estimated tax obligations for the 2018 tax year. Fortunately, the Internal Revenue Service (IRS) released Information Release and Notice (IR) 2019-55 expanding the guidance for penalty relief relating to the underpayment of individual income [...]
This is the sixth article in the Freedom Of Information Act Requests (FOIAs) and Government Data Practices Act Requests (GDPAs) series. This series is intended to provide taxpayers and practitioners with answers to the most commonly asked questions relating to the use of FOIAs and GDPAs. The use of FOIAs and GDPAs allow taxpayers and [...]