Appearing in the October of 2021 issue of ALI CLE’s The Practical Lawyer is an article by Kathleen E. (Splett) Pfutzenreuter and Benjamin A. Wagner addressing a variety of tax topics that small and solo firm lawyers should be ready to answer. The tax topics covered include: when to talk to a tax accountant or [...]
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 [...]
The United States Tax Court (Court) recently issued a decision highlighting, yet again, the importance of clear drafting in settlement agreements. In Doyle v. Comm’r of Internal Revenue, T.C. Memo. 2019-8, the Court held that the taxpayer could not exclude amounts, pursuant to Internal Revenue Code § 104(a)(2), that he received from a settlement agreement. [...]
The Internal Revenue Service (IRS) can utilize its jeopardy levy function (i.e., taking a taxpayer’s assets) to pursue a taxpayer’s assets prior to issuing a jeopardy assessment (i.e., telling a taxpayer how much they owe). In Chief Counsel Advice (CCA) 201830013, the IRS clarified the circumstances in which it would take such drastic steps. In [...]