Is the IRS Bound by It’s Letters and Notices?

If the IRS sends a taxpayer a letter saying that it will process their refund claim but then it fails to do so, is the IRS bound by its letter? The court ...
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Payments to Foreign Student Studying in U.S. Subject to Tax

We get quite a few questions from students who are in the U.S. on student visas as to whether their research awards are taxable in the U.S. The answer depends in large ...
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Congress Provides Significant Relief for Back Taxes

There are winners and losers when it comes to the recent tax changes proposed by Congress. As it turns out, those who owe back taxes to the IRS may be in the ...
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IRS Cannot Use Court to Collect from Third Party Located in Another State

The IRS has a number of collection tools at its disposal. This includes the ability to take the taxpayer’s property without court intervention. This power doesn’t extend to all property. For example, ...
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Valuation of Management Fees Paid by Related Parties

Related party transactions can raise difficult tax questions. This is especially true for management fees paid by one legal entity to another legal entity that has the same or similar owners or ...
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IRS Rejects Court’s Passive Activity Loss 5% Owner and Grouping Decision

The passive activity loss (“PAL”) rules can limit the ability to deduct losses from passive activities, such as rental losses.  The real estate professional and activity grouping rules can allow taxpayers to ...
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Stock vs. Asset Sales and Purchase Price Allocations

Buying or selling a business can present a number of challenges. One of the most basic–and often most challenging–is the decision to enter into an asset or a stock sale. There are ...
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Making the IRS Pay for Unlawful Collection Activities

Taxpayers often feel helpless when it comes to the IRS. We hear this from clients when there is some real or perceived injustice involving the IRS. While the IRS and IRS employees ...
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Court Considers Medical Marijuana Company Substantiation

Medical marijuana companies face a number of challenges. The Section 280E limitation on business deductions is one example. There have been a number of court cases that address this limitation. The Feinberg ...
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The IRS Levy, What You Need to Know

If you owe the IRS back taxes, you need to know about the IRS levy.  This is the primary tool the IRS uses to collect unpaid taxes. About the IRS Levy The ...
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