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Fraudulent Transfers Tax Planning

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Successor Liability for Unpaid Taxes

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Generally, the purchaser of assets does not assume the liabilities of the seller.  Successor liability, however, is an exception to the general rule. Under the successor-liability doctrine, the IRS may seek to recover unpaid...more

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Tax Court in Brief – Slone v. Commissioner

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Tax Litigation: The Week of February 7 – February 11, 2022 Williams v. Commissioner Slone v. Commissioner Slone v. Comm’r, T.C. Memo 2022-6 | February 7, 2022 | Lauber, J. | Dkt. Nos. 6629-10, 6630-10, 6631-10, 6632-10...more

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What Can the State of Texas Do to Collect State Taxes?

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So, the Texas Comptroller of Public Accounts (“Comptroller”) says you owe state tax. If the deficiency determination hasn’t yet become final, you still may be able to challenge the underlying tax liability (for more on that,...more

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Alter Ego and The Fifth Circuit Court of Appeals: Texas Business Owner Personally Liable for His Corporation’s Failure to Pay...

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In a recent case before the Fifth Circuit Court of Appeals, the court was faced with the following question: Whether a business owner could be held personally liable for his corporation’s failure to pay taxes.  Its answer?...more

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The IRS, Fraudulent Transfers, and Transferee Liability

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Can you be held liable for a tax liability owed by another taxpayer?  Yes, under certain circumstances.  The IRS  uses fraudulent transfer law and “transferee” liability tools to collect unpaid taxes where a taxpayer has...more

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

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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

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