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“FedEx Express Saver” is NOT Valid for Filing of a Timely Tax Court Petition (or Tax Return)

Following the examination of a taxpayer’s tax return, the Internal Revenue Service (IRS) might issue a Notice of Deficiency setting forth the proposed adjustments to a taxpayers tax return and the resulting liabilities for tax, interest and penalties arising from the underlying examination. Section 6213(a) of the Internal Revenue Code (Code) provides that, without having … Continue reading “FedEx Express Saver” is NOT Valid for Filing of a Timely Tax Court Petition (or Tax Return)

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New FBAR Form 114 and Revised IRS Appeals Procedures re FBAR Penalties

On October 28, 2013 the IRS revised the Internal Revenue Manual (IRM) providing guidance and clarification regarding the administrative review of FBAR penalties by the IRS Office of Appeals. See http://www.irs.gov/irm/part8/irm_08-011-006.html The IRM is essentially the operational manual providing guidance and procedures for the various functions carried out by the IRS. The Office of  Appeals … Continue reading New FBAR Form 114 and Revised IRS Appeals Procedures re FBAR Penalties

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IRS Warns of Telephone Scam Targeting Taxpayers, Including Recent Immigrants

The Internal Revenue Service warned consumers about a sophisticated phone scam targeting taxpayers, including recent immigrants, throughout the country. SeeIR-2013-84 (Oct. 31, 2013) at irs.gov NOTE: THE IRS WOULD RARELY, IF EVER, FIRST CONTACT A TAXPAYER BY TELEPHONE. THE FIRST CONTACT IS TYPICALLY IN WRITING AND WOULD BE RECEIVED BY U.S. MAIL. THE IRS WILL … Continue reading IRS Warns of Telephone Scam Targeting Taxpayers, Including Recent Immigrants

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Tax Practice Tool: IRS Audit Techniques Guides

Historically, Internal Revenue Service examiners were assigned to audit taxpayers in many different industries. On one day, an examiner audited a grocery store and on the following day the examiner may have audited a computer retailer or a medical doctor. As a result, experience gained in one audit did not significantly enhance the examiner’s experience … Continue reading Tax Practice Tool: IRS Audit Techniques Guides

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October 15th Deadline Remains in Effect for Taxpayers Who Requested a Six-month Extension to File Tax Return

The current lapse in federal appropriations does not affect the federal tax law, and all taxpayers should continue to meet their tax obligations as normal. Individuals and businesses should keep filing their tax returns and making deposits with the IRS, as required by law. The Internal Revenue Service reminded taxpayers that the Oct. 15 deadline … Continue reading October 15th Deadline Remains in Effect for Taxpayers Who Requested a Six-month Extension to File Tax Return

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A Temporary and Transitory Visit with California Residency

Residency determinations are relevant for purposes of marital dissolutions, education, probate proceedings, property tax determinations, voter’s registration and . . . income taxes. Individuals often believe they are not California residents for tax purposes simply because they spend significant amounts of time or maintain homes outside California. These individuals are often surprised when facing an … Continue reading A Temporary and Transitory Visit with California Residency

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IRS Operations During The Lapse In Appropriations

IRS Operations During The Lapse In Appropriations Release Date: OCTOBER 01, 2013 Due to the current lapse in appropriations, IRS operations are limited. However, the underlying tax law remains in effect, and all taxpayers should continue to meet their tax obligations as normal. Individuals and businesses should keep filing their tax returns and making deposits … Continue reading IRS Operations During The Lapse In Appropriations

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Zwerner Answers DoJ Efforts to Collect Multiple 50 Percent Civil FBAR Penalties

U.S. taxpayers with previously undisclosed interests in foreign financial accounts and assets continue to analyze and seek advice regarding the most appropriate methods of coming into compliance with their U.S. filing and reporting obligations. Many are pursuing participation in the current IRS offshore voluntary disclosure program (the OVDP which began in 2012), modeled after similar … Continue reading Zwerner Answers DoJ Efforts to Collect Multiple 50 Percent Civil FBAR Penalties

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You Should Also Worry About Refund Statute of Limitations by Edward M. Robbins, Jr.

  It is critical to understand the intricacies and the interrelationships of the refund and assessment statutes.  The general rule is that the period of limitations for the taxpayer to file a claim for refund and for the IRS to make an assessment is 3 years from the date the tax return is filed.1  The … Continue reading You Should Also Worry About Refund Statute of Limitations by Edward M. Robbins, Jr.

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You Should Worry About Section 6501(c)(8) by Edward M. Robbins, Jr.

Most tax practitioners understand the basic assessment statute of limitations rules in the Code: three years after the return is filed, six years after the return is filed for 25% omission of income, or forever in the case of fraud and/or failure to file.[i]  Practitioners may be less familiar with the raft of additional special … Continue reading You Should Worry About Section 6501(c)(8) by Edward M. Robbins, Jr.

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Part III: Six IRS Letters and Notices You Must Not Ignore by Edward M. Robbins, Jr.

We finish this three-part discussion by discussing the final two IRS letters and notices cannot be ignored without serious adverse legal consequences for the taxpayer.  The taxpayer must not ignore these two IRS letters and notices! 5.  Statutory Notice of Disallowance of a Claim for Refund Ignoring this notice is catastrophic if the taxpayer is interested … Continue reading Part III: Six IRS Letters and Notices You Must Not Ignore by Edward M. Robbins, Jr.

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Tax Consequences Resulting From Renouncing U. S. Citizenship by Lacey E. Strachan

The U.S. is among the few industrialized countries that taxes citizens who live  abroad, even if their income is entirely sourced in a foreign country. It is believed an estimated 6 million Americans live outside the United States but otherwise remain subject to taxation by the U.S. During the past year, an estimated 1,800 people … Continue reading Tax Consequences Resulting From Renouncing U. S. Citizenship by Lacey E. Strachan

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