The Presumption of Innocence Podcast: Episode 44 - A Recipe for Litigation: The Simmering Conflict Surrounding ERC Claims
REFRESH Nonprofit Basics: Navigating the Complex Rules That Describe a Public Charity
Expedited Review of IRS Applications for Recognition of Exempt Status
Nonprofit Quick Tip: State Filings in New Mexico and Utah
Back to Compliance: Reinstating Tax-Exempt Status for a Charity
PODCAST: Williams Mullen's Benefits Companion - IRS Clarifies Emergency Distributions Tax Exceptions
GILTI Conscience Podcast | Spotlight Series: A Celebration of Pride Month With IRS Veteran De Lon Harris
Nonprofit Quick Tip: State Filings in Oklahoma and Texas
Inflation Reduction Act Tax Trends Begin to Take Shape
Advice for Nonprofit Investment Committees From an Investment Advisor June 3, 2024 Podcast
REFRESH: Loot and Private Foundation Rules – Part 2
IRS Dirty Dozen Warnings on Charitable Scams
US Expatriate Tax Planning - Part 1 - A Podcast with Janathan Allen
Nonprofit Quick Tip: State Filings in North Carolina and South Carolina
Nonprofit Quick Tip: State Filings in Florida and Louisiana
Business Better Podcast Episode: Tax Audits, Investigations, and Global Enforcement - A Conversation with IRS Special Agent Jonathan Schnatz
4 Key Takeaways | Harnessing the Inflation Reduction Act: Driving Investments in Renewable Energy and Carbon Reduction
Nonprofit Basics: Scholarship Grant Program IRS Approval Requirements
Nonprofit Quick Tip: State Filings in Rhode Island and New Hampshire
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Private Foundation Advocacy
Q: I have a client who owes money to the IRS. While I know the IRS likely has a tax lien, my understanding was it just waits until a taxpayer’s property is sold and then gets paid out of escrow. Instead, here, the IRS has...more
So starts the opinion of the United States Court of Appeals for the Ninth Circuit in United States v. MacKenzie: “As Benjamin Franklin said, ‘nothing is certain except death and taxes.’ But how certain are taxes in a Chapter...more
In Ryckman v. Commissioner, the U.S. Tax Court tackled an issue of first impression: whether it has jurisdiction over a case challenging the denial by the Internal Revenue Service (“IRS”) of a collection due process (“CDP”)...more
Q: I was appointed receiver over a manufacturing facility. I operated it for a short time and then obtained court authority to sell it. I netted $1.4 million from the sale....more
An anonymous thinker, lost to history, is credited with having said that the unofficial motto of the IRS is, “We have what it takes to take what you have.” In some instances, the truth of the above statement is manifested in...more
Introduction: What is Estate Tax and Who Has to Pay? Over 200 years have passed since Benjamin Franklin famously wrote, “in this world, nothing can be said to be certain, except for death and taxes.” This sentiment still...more
Los contribuyentes tienen derecho a apelar al IRS. Entender cómo apelar al IRS es fundamental y los contribuyentes deben considerar contratar representación para disminuir los riesgos de litigio. Sólo los abogados, contadores...more
Taxpayers have the right to appeal the IRS. Understanding how to appeal the IRS is critical and Taxpayers ought to consider retaining representation in order to diminish the risks of litigation. Only attorneys, certified...more
Death of a Parent- In the context of a family-owned business, it is often the case that the matriarch or patriarch of the family is also the chief executive of the business. They may have founded the business, or they may...more
El IRS había suspendido ciertas actividades de cobro, incluyendo la certificación de pasaportes en respuesta a la pandemia de COVID-19; sin embargo, desde 2021, el IRS retomó su proceso de certificación de pasaportes ante el...more
Summary: In this collection due process (CDP) case, Mehlek Dawveed sought review of the determination by the IRS to uphold a notice of Federal tax lien (NFTL) and a notice of intent to levy for 2010. The IRS took these...more
The IRS has increased its practice to issue Notices of Deficiency without an audit. For example, if there is a mismatch between what was reported on a Form 1099 for a taxpayer and the income shown on the taxpayer's return, or...more
The IRS had suspended certain collection activities including passport certification in response to the COVID-19 pandemic; however, since 2021, the IRS resumed its passport certification process to the U.S. Department of...more
Summary: Petitioners, Willard Belton and Martha-Alexander Belton (Petitioners or Beltons) seeks review pursuant to section 7345(e), challenging the IRS’s certification to the Secretary of State that Petitioners had a...more
Summary: Petitioner, Blake M. Adams, seeks review pursuant to section 7345(e) of the IRS’s certification to the Secretary of State that Adams has a “seriously delinquent tax debt” related to tax years 2007, 2009, 2010, 2011,...more
Tax Litigation: The Week of December 5th, 2022, through December 9th, 2022 - Mattson v. Comm’r, T.C. Memo. 2022-118 | December 6, 2022 |Copeland, J. |Docket No. 16982-18P - Summary: Eric Mattson did not file income tax...more
Overview - Most of you know that I am a big music fan. I have always liked Joe Cocker. The song The Letter is a song that was originally performed by The Box Tops and was a Number 1 hit in 1967. The song was covered by Joe...more
In 2021, the Internal Revenue Service filed 212,251 Notices of Federal Tax Lien (“NFTLs”). To provide perspective, in 2019 (i.e., pre-COVID-19 pandemic), the IRS filed 543,604 NFTLs. The IRS is working on ramping up its...more
Tax Litigation: The Week of September 19th, 2022, through September 22nd, 2022 Vorreyer v. Comm’r / Thoma v. Comm’r / Dowson v. Comm’r, T.C. Memo 2022-97| September 21, 2022 | Greaves, Judge | Dkt. Nos. (Consolidated)...more
Tax Litigation: The Week of July 11th, 2022, through July 15th, 2022 Colbert v Commissioner, T.C. Memo. 2022-74 | July 13, 2022 |Wells, J.| Dkt. No. 8395-16. Knight v. Comm’r, T.C. Memo. 2022-76| July 14, 2022 | Lauber, A. |...more
Tax Litigation: The Week of June 27th, 2022, through July 1st, 2022 Serna v Commissioner, T.C. Memo. 2022-66 | June 27, 2022 | Urda, J.| Dkt. No. 13202-19L Pedersen v. Commissioner, T.C. Summary Opinion 2022-11 | June 28,...more
The IRS sends a CP504 Notice when a taxpayer has failed to pay a balance owed. The CP504 Notice is a Notice of Intent to Levy issued pursuant to Section 6331(d) of the Internal Revenue Code. If a taxpayer fails to make...more
Under the Internal Revenue Code, the IRS can satisfy a tax deficiency by imposing a lien on any “property” or “rights to property” belonging to the taxpayer. The statutory language is broad and reaches virtually every...more
Tax Litigation: The Week of March 14, 2022, through March 18, 2022 AptarGroup, Inc. v. Comm’r, 158 T.C. No. 4 | March 16, 2022 |Goeke, J. | Dkt. No. 7218-2 Pickens Decorative Stone, LLC v. Comm’r, T.C. Memo. 2022-22 | March...more
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....more