Tax Blog

Avoiding Cancellation of Debt Using Rebates or Refunds

Can taxpayers avoid cancellation of debt income by structuring debt reductions as rebates or refunds?  The court touched on this issue in French v. Commissioner, T.C. Summary Opinion 2018-36. The Facts & Procedural ...
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The Last Filed Rule Overruled? IRS Collections Now Uncertain

Taxpayers will often file tax returns that do not report all of their allowable deductions and credits, with the intent of going back and filing amended returns once they are able to ...
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Avoiding an IRS Wage Levy by Change to Contractor Status

Can you avoid an IRS wage levy by having your employer change your status from that of an employee to a contractor?  The court addressed this in Hudiak vs. United States, No. MJG-11-1271 ...
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Construing Tax Laws Tied to Activities, Time for a New Rule?

When Congress provides a tax benefit contingent on some activity, there is often a question as to whether the activity can be read broadly to encompass many sub-activities or has to be ...
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Independent Administration in Texas

Probate Law Blog Houston Probate Attorney What is an independent administration? An independent administration is a non-court administration.  After a person has applied for letters testamentary and been qualified as independent executor by ...
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Perception Can Be As Important as Substance in Tax Disputes

Taxpayers voluntarily submit information to the IRS.  The IRS not only evaluates the substance of this information, but also the taxpayer’s candor in preparing and providing the information.  The perception of candor ...
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Letters Testamentary and Letters of Administration in Texas

Probate Law Blog Houston Probate Attorney Letters testamentary and letters of administration – citations After a person passes away and leaves behind property to be administered, one of the first steps is ...
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What is a Family Settlement Agreement?

Probate Law Blog Houston Probate Attorney About Family Settlement Agreements in Texas Family settlement agreements are used to resolve probate litigation without trial. They can help avoid litigation costs and uncertainty associated ...
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Probate Adminstration in Texas

Probate Law Blog Kunal Patel What is Probate? The probate process is a legal process in which an instrument is judicially determined to be the executed last will of a decedent, or ...
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Loaning Money to Business Triggers Trust Fund Penalty

You work hard to build a business, you find success over the years, and then you find out that your long term accountant did not remit payroll taxes and you owe a ...
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