The Internal Revenue Service (IRS) can file a lien and levy on any and all of a taxpayer's property (and rights to property) regardless of how the property is held or titled. 26 U.S.C. ยง 6321. Whether the item is a taxpayer's...more
7/26/2021
/ Appeals ,
Beneficiaries ,
Civil Code ,
Estate Planning ,
Executors ,
IRS ,
Liens ,
Life Estates ,
Mineral Rights ,
Personal Property ,
Property Ownership ,
Stock Sale Agreements ,
Tax Debt ,
Tax Levy
In Notice 2004-45, 2004-2 C.B. 33, the IRS put taxpayers who were asserting to be bona fide residents of the U.S. Virgin Islands (USVI) and who were not following the requirements of meeting the applicable bona fide residency...more
3/10/2021
/ Appeals ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Large Business & International Division (LB&I) ,
Puerto Rico ,
Remand ,
Residency Requirements ,
Statute of Limitations ,
Tax Court ,
Tax Returns ,
Virgin Islands
The American Recovery and Reinvestment Act of 2009 (ARRA) Section 1603 provided a cash grant (Grant) for "specified energy property" (as defined in ARRA Section 1603(d)). Specified energy property, within the meaning of ARRA...more