Private Letter Ruling 202244002, November 4, 2022 - In a recent Private Letter Ruling, the Internal Revenue Service granted a partnership 120 days from the date of the letter to make an election under §754 of the Internal...more
Case: Szczyporski v. Internal Revenue Service (In re Szczyporski), No. 21-01858 (3d Cir., May 11, 2022).
In a recent case out of the 3rd Circuit, the Court of Appeals affirmed a ruling emanating from the Bankruptcy...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
One of the little-known tools in the IRS collection tool belt is the ability to revoke a taxpayer’s passport where the taxpayer has a “seriously delinquent tax debt.”...more
The recent bankruptcy case of In re Creative Hairdressers, Inc. et al, Case Nos. 20-14583 and 20-14584 (jointly administered) (Bankr. D. Md., March 3, 2022) involved the intersection of IRC section 4980H‘s employer shared...more
Case: In re Shaikh, Case No. 19-80436-TLM (Bankr. E.D. Okla., March 4, 2022) - This case addresses an intersection of tax and bankruptcy law related to tax refunds. Specifically, it looks at the issue of whether and when...more
This post focuses on the recent case of Polselli, et al. v. IRS, Case No. 21-1010 (6th Cir., January 7, 2022).
The recent Sixth Circuit’s recent opinion in Polselli, et al. v. IRS, Case No. 21-1010 (6th Cir., January 7,...more
In re Kent Culp, Case No. 20-52558 (Bankr. E.D. Mich., July 29, 2021) - This recently issued case from the Bankruptcy Court for the Eastern District of Michigan addresses an interesting intersection of bankruptcy and tax law...more
A topic that doesn’t get a whole lot of attention from tax professionals is “Currently Not Collectible” (“CNC”) status, which is a status that your account with the IRS may obtain when you cannot currently afford to pay the...more
A topic that we frequently see in the Tax Clinic that I run, one that is often misunderstood, is that of innocent spouse relief. Generally, the purpose of providing innocent spouse relief is to, as one court put it: ...more
This program is the first of Freeman Law’s multi-class course designed to prepare CPAs and Enrolled Agents for the Tax Court’s admissions examination. Participants will receive an overview of the Tax Court and will learn...more
8/19/2021
/ CPAs ,
Estate Tax ,
Federal Rules of Evidence ,
Gift Tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Legal Ethics ,
Subject Matter Jurisdiction ,
Tax Court ,
Tax Litigation ,
Webinars
The recent case of In re Bowman, Case No. 20-11512, Section A (Bankr. E.D. La., July 12, 2021) addresses an interesting intersection of tax and bankruptcy law. Specifically, it looks at the issue of whether bankruptcy courts...more
Join us as we discuss important developments and bring you up to speed on current initiatives. Many businesses are still facing unprecedented challenges, and we are here to provide insights.
During this information-filled...more
7/23/2021
/ Automatic Stay ,
Cryptocurrency ,
Enforcement ,
Income Taxes ,
IRS ,
Reasonable Compensation ,
State Taxes ,
Tax Benefits ,
Tax Court ,
Tax Litigation ,
Tax Planning ,
Webinars
Case: In re Moreno, 127 AFTR 2d 2021-1946, Case No. 20-42855 (Bankr. W.D. Washington, May 11, 2021).
This case focuses on bankruptcy exemptions applicable in the State of Washington to certain amounts received by the...more
The dischargeability of and the ability to collect taxes by the IRS in a consumer bankruptcy case often turn on the issue of whether and when the taxpayer filed the relevant returns, thereby determining when the statute of...more