Straddle-Year Tax Debts in Bankruptcy: Does the King Get Paid First? [More with McGlinchey, Ep. 14]
You may recall that earlier this year the IRS launched an initiative to pursue 125,000 “high-income, high-wealth” taxpayers who have not filed taxes since 2017. These were cases where the IRS received third party information...more
On 5/4/24, the U.S. Department of the Treasury and the IRS outlined the accomplishments achieved in the first year of implementation of the Strategic Operating Plan, a comprehensive roadmap to transform the IRS using...more
En su mayor parte, los contribuyentes no quieren recibir correo del IRS ni abrir correo del IRS. Es por eso por lo que el IRS emitió el Consejo Fiscal (“Tax Tip”) 2024-45 el 6 de mayo de 2024 para informar a los...more
For the most part, Taxpayers do not want to receive mail from the IRS or open mail from the IRS. This is why IRS issued Tax Tip 2024-45 on May 6, 2024 to let taxpayers know what taxpayers should do if they receive mail from...more
El IRS emitió el Consejo Fiscal 2024-37, el 24 de abril de 2024, para informar a los contribuyentes que no pueden pagar su deuda tributaria completa o si pagar les causaría dificultades financieras, que deberían considerar...more
IRS issued Tax Tip 2024-37, April 24, 2024, to inform taxpayers that can’t pay their full tax debt or if paying would cause financial hardship, that they should consider applying for an offer in compromise which is a program...more
Imagine the IRS notifies Taxpayer that they have an outstanding tax liability with respect to Tax Year, and that the agency intends to levy on Taxpayer’s property to collect the allegedly unpaid tax. Taxpayer challenges the...more
On April 3, 2024, the Brazilian Internal Revenue Service (“Brazilian IRS”) published Normative Instruction RFB No. 2,184 (“IN/RFB No. 2,184/2024“), regulating a special program to incentivize the voluntary disclosure of...more
Thanks to a dramatic increase in funding courtesy of the Inflation Reduction Act of 2022, the Internal Revenue Service recently announced several new, high-profile enforcement initiatives designed to generate significantly...more
The IRS expects to send out over 125,000 collection letters to high-income taxpayers who did not file one or more federal income tax returns between 2017 and 2021. As part of the new collection initiative, approximately...more
Avisos de Cobros del IRS se reiniciarán en 2024 así como un nuevo alivio de multas para aproximadamente 4.7 millones de personas, empresas y organizaciones exentas de impuestos a las que no se les envió un recordatorio...more
On 12/19/23, the IRS announced the restart of IRS collection notices as well as a new penalty relief for approximately 4.7 million individuals, businesses and tax-exempt organizations that were not sent an automated IRS...more
As practitioners predicted, the California Franchise Tax Board has adopted the federal November 16, 2023 extensions for similar state returns and payments. To those CPAs and taxpayers who pulled all-nighters to get returns...more
In a rare unanimous opinion, the U.S. Supreme Court recently confirmed that existing law allows the IRS to probe your bank records, without ever notifying you. Under the applicable statute, the Court concluded the IRS is not...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 24, 2023 – April 28, 2023...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
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 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
Tax Litigation: The Week of May 30th, 2022, through June 3rd, 2022 Ezekwo v Commissioner, T.C. Memo. 2022-54 | May 31, 2022 | Lauber, J.| Dkt. No. 15454-21P...more
Once the IRS makes an assessment against a taxpayer, the taxpayer will receive several notices before the IRS takes enforced collection action....more
In The Bank of Nova Scotia v The Queen, the Tax Court of Canada (TCC) considered how to calculate arrears interest on an audit adjustment that is offset by a loss carryback. ...more
Many people end up owing the IRS for many reasons and there are various options to resolve your tax debt. Some of the options include an offer in compromise, installment agreement, or currently non-collectible status....more