Tax Blog

U.S. Taxpayer With U.S. Residence Cannot Exclude Foreign-Earned Income

There are a number of tax issues that U.S. citizens and residents who live abroad have to consider.  One of these is whether they qualify to exclude their foreign-earned income in computing ...
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Documenting Tax Losses for Worthless Securities

Tax losses for worthless securities are often challenged by the IRS.  It particularly important to document the loss.  There are several elements taxpayers have to establish to secure the benefit of tax ...
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Court May Explain How to Allocate Tax Basis to Intangible Assets

If the U.S. government allows a taxpayer to call a liability an asset and then acts to make the asset worthless, can the taxpayer take a tax loss for the loss of ...
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IRS Can Use Probate Process to Extend Collection Period

When a loved one dies, the person who serves as the personal representative is tasked with wrapping up the decedent’s affairs and paying known creditors.  But what if one of the creditors ...
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The IRS Isn’t Charged With Knowledge of Other Federal Agencies

The IRS only has to mail a notice of deficiency to a taxpayer’s last known address in order to assess or record a tax liability for the taxpayer.  This “last known address” ...
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IRS Installment Agreement Calculation Counts Spendthrift Trust Distributions

The IRS generally cannot reach funds in a spendthrift trust to satisfy the trust beneficiary’s unpaid tax debts.  But can the IRS factor in trust distributions in calculating the how much the ...
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Donations to Pastor are Taxable Income, Not Gifts

The distinction between taxable compensation and non-taxable gifts comes up in a number of contexts and has led to a number of tax disputes.  Severance payments made to workers are an example.  ...
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IRS Can Collect from Property Purchased in Corporation

Can a taxpayer put property beyond the IRS’s reach by purchasing the property in the name of a corporation or a third party?  The answer is typically “no.”  The recent Arlin Geophysical ...
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Planning for Start-Up Businesses, Yacht Rental Example

New businesses may not be immediately profitable.  To help mitigate the financial risk, many businesses are started by workers who have a day job.  If the business is not immediately profitable it ...
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Family Member’s Mortgage Filing May Trump IRS Lien

If a child owes unpaid taxes to the IRS, can the parent file a lien against the child’s property to prevent the IRS from levying on the property?  The court considered this ...
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