Our Blog

The Effect of Latent Tax Liabilities on Stock Values by Avram Salkin

The IRS has consistently taken the position that potential tax liabilities of C corporations, S Corporations, and individuals should not be considered when valuing stock or other assets.  For example, should the stock of an S Corporation’s stock be reduced if the corporation holds assets that are worth far more than their tax basis?  If […] Read More…

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How Long Should I Keep Tax Records?

Many taxpayers hoard records such that they can be appropriately prepared “if and when” an IRS examination occurs. Others often inquire as to which records should be maintained and for how long. Some routinely destroy relevant documents on the mistaken belief that an examination result will somehow be enhanced if certain documents simply don’t exist. […] Read More…

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Random Thoughts re IRS Examination Representation

It is extremely important to have a working knowledge and appreciation for the administrative process in which tax returns are fi led, reviewed and examined. This knowledge allows the practitioner an opportunity to provide an efficient, invaluable service to his clients and to the system of tax administration. The administrative process should not be abused […] Read More…

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AGOSTINO & ASSOCIATES NEWSLETTER – The Taxpayer Advocate Service: Guarantors of the Taxpayer Bill of Rights

AGOSTINO & ASSOCIATES –To download a great article prepared by our very close friends at the Law Firm of Agostino & Associates in Hackensack, NJ ( www.agostinolaw.com ), see the Agostino & Associates November Newsletter https://drive.google.com/file/d/0B719qAMBEjGQUjlDb3VJTDVkZDA/view?pli=1 The Taxpayer Advocate Service – Guarantors of the Taxpayer Bill of Rights By Frank Agostino & Matthew Turtoro –  The Taxpayer Advocate Service […] Read More…

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Voluntary Disclosures by Non-Filers

Practitioners often struggle with the issue of whether a taxpayer can avoid a criminal tax investigation by making a disclosure to the IRS. A “voluntary disclosure” generally involves the process of contacting the IRS in some manner and voluntarily reporting previously undisclosed income (or false deductions) through an amended return or the filing of a […] Read More…

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Warning Signs of an IRS Criminal Tax Prosecution Referral

Every IRS examination potentially involving tax fraud requires a thorough examination of not only what transpired but, almost more importantly, why something did or did not transpire. Tax practitioners must understand the process by which a civil tax case winds its way through the system. Identifying the decision-makers and the factors they consider important may […] Read More…

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IRS: Common Badges of Tax Fraud

Section 6663(a) provides that, if any part of an underpayment is due to fraud, there shall be added to the tax an amount equal to 75% of the portion of the underpayment which is attributable to fraud. The IRS bears the burden of proving by clear and convincing evidence that: (1) An underpayment of tax […] Read More…

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IRS Interviews of Taxpayers and Return Preparers

Requests to interview the taxpayer and/or return preparer during an otherwise normal IRS examination have become somewhat common. During the examination, the examining agent is auditing the return for accuracy and the taxpayer’s representative is typically trying to determine the nature and scope of the examination, gather responsive documents and information, etc. It is nearly impossible […] Read More…

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Bankruptcy (Tax) Law Must Apply Equally to the Rich and Poor Alike . . .

Generally, subject to certain statutory exceptions, a debtor is permitted to discharge all debts that arose before the filing of his bankruptcy petition.[1] With respect to tax debts, the Bankruptcy Code provides that a debtor may not discharge any tax debts “with respect to which the debtor made a fraudulent return or willfully attempted in […] Read More…

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Voluntary Disclosure – Benefits of Timely Filing Amended and Delinquent Tax Returns

Voluntary Disclosure. Practitioners often struggle with the issue of whether a taxpayer can avoid a criminal tax investigation by making a disclosure to the IRS.  A “voluntary disclosure” is generally the process of voluntarily reporting previously undisclosed income (or false deductions) through an amended return or the filing of a delinquent return. A taxpayer’s timely, […] Read More…

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IRS Non-Filers Beware: Who’s That Knocking at Your Door ?

For numerous reasons, many taxpayers fail to timely file required U.S. income tax returns and associated reports. A “non-filer” is described as a taxpayer (or someone who ought to be a taxpayer) who does not file their return before the deadline to file the next year’s return. A “late filer” is taxpayer who misses the […] Read More…

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AGOSTINO & ASSOCIATES NEWSLETTER – De Novo Review of Assessable International Penalties

AGOSTINO & ASSOCIATES –To download a few great articles prepared by our very close friends at the Law Firm of Agostino & Associates in Hackensack, NJ ( www.agostinolaw.com ), see the Agostino & Associates Newsletter https://doc-0g-a0-apps-viewer.googleusercontent.com/viewer/secure/pdf/3nb9bdfcv3e2h2k1cmql0ee9cvc5lole/a2e9d5ia6l9d8arb24i9qe55u5g1r2jr/1409675775000/drive/*/ACFrOgB3DcF0a_jTmvIpYCiuNKqO7L9fgn3s-OoYgXI80f841xzDJ5w3W4RQJIos9LXs1ctCT2z8v3FIziSDS2y-W6ct63hwuBzvEW_vnXAgbmb31pJpOwZuVMW1Ou8=?print=true DE NOVO REVIEW OF ASSESSABLE INTERNATIONAL PENALTIES By Frank Agostino, Brian D. Burton, and Lawrence A. Sannicandro    – Many taxpayers and […] Read More…

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