Knowledge is Power when negotiating with the IRS. You must know what they know to be successful. I want to help you obtain that knowledge. This is a short introductory video to tell you a little bit about myself and the TAX videos discussed on my Channel.
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A hard lesson for US taxpayer owners, settlors, or beneficiaries of foreign trusts was recently handed down in Emily S. Wilson et al. v. United States; No. 20-603. A U.S. citizen, by such relation to a foreign trust has the requirement to file IRS Form 3520 and IRS Form 3520-A annual returns. Failure to do
In part, below is an excerpt from the publication of Procedurally Taxing, published August 24, 2021, and it is very instructive concerning the importance of the Hardship factor in making Innocent Spouse claims.
Research of innocent spouse cases shows that proving financial hardship serves as the only way to guarantee that the taxpayer wins
Three recent Federal Court cases, Premier Tech v. United States, No. 2:20-cv-890-TS-CMR (D. Utah 2021); Intermountain Electronics v. United States, No. 2:20-cv-00501-JNP (D. Utah 2021); and Harper v. United States, 847 F. Appx. 408 (9th Cir. 2021), remind taxpayers of the “specificity” requirements in making Claims for Refund. While we will not delve into each
I have written previously on this Blog and for Cointelegraph on the Jarrett v. Commissioner case filed on May 26 with a Tennessee Federal District Court (Case No. 3:21-cv-00419), whereby the taxpayers sought a refund of taxes they had paid in connection with their generation of Tezos digital tokens through their proof-of-stake activities. While the
Jeopardy assessments for tax collection are rare, but they are a tool available to the IRS in extraordinary circumstances. Jeopardy assessments stand outside the normal IRS assessment procedures. In general,
and in extraordinary circumstances, jeopardy assessments permit the IRS to assess additional income taxes first and only later give the taxpayer a chance to contest
IRS Appeals Conferences may now include additional participants. After the conclusion of an IRS Appeals pilot program, the results suggest that IRS Appeals benefits from including examination teams and Chief Counsel attorneys to engage with taxpayers and their representatives at the IRS Appeals conferences. They believe it improves IRS Appeals’ ability to work large, complex
Normally, an Innocent Spouse Determination Letter denying relief is final unless a taxpayer files a Tax Court Petition to challenge the denial. If that Tax Court Petition deadline (90 days from the Innocent Spouse Determination Letter) is missed, then the taxpayer is forever stuck with the Innocent Spouse denial. However, that hard and fast rule
As a result of the IRS campaign against cryptocurrency tax noncompliance, it has received more than 1,000 amended tax returns, collected $13 million in taxes from crypto holders with more than $20,000 of transactions, and collected another $12 million from other crypto notices. Moreover, the Treasury Department has recently released the “American Families Plan Tax
The IRS is now using data analytics and article intelligence to access billions of crypto transactions in the digital world and make the process more efficient for IRS Criminal Investigators. Once your cryptocurrency becomes fiat currency and once it goes into an exchange, the IRS is able to trace it. And the IRS is quickly
