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Is Cryptocurrency “Property” for U.S. Income Tax Purposes?

Our firm has written extensively on the topic of cryptocurrency.  Indeed, we have even designated an entire resource page on our website to this always interesting and constantly evolving topic...more

DOJ-Tax Alleges President of We Build the Wall Filed a False Tax Return and Committed Wire Fraud

Taxpayers who file false tax returns with the IRS can find themselves in hot water.  Indeed, section 7206(1) of the Internal Revenue Code (“Title 26”) makes it a felony to file a false return when the taxpayer knows that the...more

How Long Can the IRS Levy on Social Security Benefits?

To levy on Social Security benefits, the IRS generally issues Form 668-W to the Social Security Administration (“SSA”). After receipt of the Form 668-W, Notice of Levy on Wages, Salary, and Other Income, SSA will withhold...more

[Webinar] Updates: IRS Tax Enforcement, Taxation of Settlements, and Cross-Border Tax Planning - August 31st, 3:00 pm CT

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

How to Designate an IRS Employment Tax Payment

When a taxpayer makes a voluntary payment to the IRS, the taxpayer has the option to designate the application of the payment to certain periods and/or taxes. For example, if a corporation owes federal employment taxes and...more

Can You Transfer Assets to Avoid Paying Taxes to the IRS?

In many cases, taxpayers attempt to transfer assets or property to third persons to shield those assets and property from the federal tax lien or federal tax levy. Predictably, the IRS has various tools at their disposal to...more

Recent Tax Court Case: Unassessed Taxes are Not Discharged in Bankruptcy

A recent Tax Court opinion demonstrates the complexities involved when a taxpayer attempts to discharge tax liabilities through bankruptcy proceedings. The case emphasizes the need for an attorney knowledgeable in both tax...more

The King of Pop, Michael Jackson’s, Estate Wins Big at Tax Court

Two things are virtually certain in life: death and taxes. But, one more should be added to the list where the two converge—an IRS audit. Indeed, this scenario played out all too well for the “King of Pop,” Michael...more

How to Successfully Request IRS Penalty Relief

Federal tax penalties have always been an IRS priority.  But, perhaps more so today than three decades ago.  For example, in 1987, the IRS reported that it had assessed penalties of approximately $14 billion.  Compare that...more

IRS Publishes Proposed BBA Regulations on Special Enforcement Matters

Over 5 years ago, then President Obama ushered in sweeping changes to the method and manner in which partnerships are audited and partnership tax is assessed and collected through his signing of H.R. 1314, the Bipartisan...more

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