Form 2848 Must Specifically List Information Tax Returns

The IRS can generally disclose a taxpayer’s tax information with a representative that is designated by the taxpayer on a Form 2848, Power of Attorney and Designation of Representative.  This covers all ...
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Revocation of Nonprofit Status Triggers Retroactive Interest

There are some areas of law where principles of equity and good faith play a big role. By and large, tax law does not adopt these principles. The CreditGUARD v. Commissioner, 149 ...
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IRS Benefits from the Texas Homestead Exemption

In United States. v. Cobos, No. 3:13-CV-4924-L (N.D. Tex. 2017), the court addressed whether a third party who files a lien notice against a taxpayer before the IRS files its lien notice ...
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Amending Tax Returns for FTC and NOL Carrybacks

The time limits for filing amended tax returns can present a number of difficult questions.  This is particularly true when tax attributes, such as foreign tax credits and net operating loss deductions, ...
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Court Says Rent Income from S Corp Not Subject to Self-Employment Taxes

In Martin v. Commissioner, 149 T.C. 12 (2017), the court concluded that S corporation shareholders can avoid self-employment taxes by holding their farming operations in their S corporation. While the court case ...
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Court Denies IRS Injunction in Employment Tax Dispute

It is common for the IRS to make various demands on businesses that are undergoing employment tax audits or businesess that are trying to deal with employment tax collection issues. One common ...
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New IRS Directive for Auditing Current Year Wage QREs

The IRS’s LB&I Commissioner released a new directive about how certain qualified research expenses will be audited. We have already received inquiries as to whether clients should attempt to comply with the ...
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Can the IRS Keep My Refund to Pay My Spouses Tax Debts?

Will you receive a tax refund from the IRS if you marry someone who owes back taxes to the IRS? If the IRS keeps your refund for the current year to pay ...
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U.S. Treasury Says IRS Not Using Information from Foreign Governments

It wasn’t long ago that the IRS was completely in the dark as to what information taxpayers and others were reporting to foreign governments. The IRS would never show up on U.S ...
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Court Says Deduction for Tax Loss Not Allowed for Worthless Debt

Tax losses for worthless debts often trigger IRS audits. On audit, it is common practice for the IRS to disallow the losses based on the debt not being worthless, the amount of ...
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