Our Blog

IRS Employment Tax Notices Must be Sent to the “Last Known Address” of the Taxpayer, by ROBERT S. HORWITZ

The IRS has recently enhanced their focus on employment tax enforcement throughout the country. An employment tax return filed by April 15 of the year following that in which the applicable quarter falls is “deemed filed” on April 15 of the following year. Where no return is filed, the three-year assessment period does not begin to run … Continue reading IRS Employment Tax Notices Must be Sent to the “Last Known Address” of the Taxpayer, by ROBERT S. HORWITZ

Read More

“GOTCHA” — UNANTICIPATED AUDIT ISSUES AFTER QUIET DISCLOSURES By Frank Agostino and Lawrence A. Sannicandro

ANOTHER GREAT ARTICLE FROM 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 February Newsletter – http://files.ctctcdn.com/f7d16a55201/5f66c5a0-157c-4050-bbdd-81087e8b2275.pdf “GOTCHA” — UNANTICIPATED AUDIT ISSUES AFTER QUIET DISCLOSURES By Frank Agostino, Esq. and Lawrence A. … Continue reading “GOTCHA” — UNANTICIPATED AUDIT ISSUES AFTER QUIET DISCLOSURES By Frank Agostino and Lawrence A. Sannicandro

Read More

IRS Transaction Codes Pocket Guide – Helpful if You Need it ! by Robert Horwitz

The IRS transaction codes are typically listed on an taxpayers transcript of account. The transaction guide identifies many of the most often used codes. “This document is an abbreviated version of the Transaction Codes listed in Document 6209 for quick reference. The transaction codes consist of three digits. They are used to identify a transaction … Continue reading IRS Transaction Codes Pocket Guide – Helpful if You Need it ! by Robert Horwitz

Read More

IRS’ Breach of a Closing Agreement – 9th Circuit Sends Al Davis Home by Lacey Strachan

In the recent decision Davis v. United States, No. 13-16458 (9th Cir. 1/25/2016), the Ninth Circuit reversed a district court decision that had invalidated certain IRS assessments against Al Davis and his wife, relating to a TEFRA partnership proceeding involving the Oakland Raiders, a California limited partnership of which Al Davis had the largest interest. … Continue reading IRS’ Breach of a Closing Agreement – 9th Circuit Sends Al Davis Home by Lacey Strachan

Read More

IRS Revises Streamlined FBAR Reporting Procedures Non-Resident Certification Form 14653

The Streamlined Filing Compliance Procedures represent an IRS effort to find a viable method of encouraging U.S. taxpayers to come into compliance with their reporting and filing requirements associated with varying interests in foreign financial accounts and assets.[i] The Streamlined Procedures require the filing of original or amended tax returns and FBARs as well as … Continue reading IRS Revises Streamlined FBAR Reporting Procedures Non-Resident Certification Form 14653

Read More

Even If You Pay Your Taxes on Time You Can Still Be Penalized by Robert S. Horwitz

Justice Oliver Wendell Holmes once wrote, “Men must turn square corners when they deal with the Government.” When you deal with the IRS, deviation from the requirements of the Internal Revenue Code and regulations can be costly, as a bank learned the hard way in Commerce Bank & Trust Co. v. United States, 2016 TNT … Continue reading Even If You Pay Your Taxes on Time You Can Still Be Penalized by Robert S. Horwitz

Read More

9100 Relief for Late Portability Elections by Krista Hartwell

Treasury recently updated the section 2010 Regulations to permit the IRS to grant 9100 relief for late portability elections. On January 2, 2013, President Obama signed into law the American Tax Relief Act of 2012 (ATRA), which made permanent portability between spouses of the estate tax annual exclusion amount. Portability allows the second to die … Continue reading 9100 Relief for Late Portability Elections by Krista Hartwell

Read More

Uncle Sam Collects Danish Taxes-The World is Becoming a Smaller Place By Steven Toscher and Robert Horwitz

A recent opinion by the U.S. District Court in the Northern District of Georgia in Dileng v. Commissioner, 1:15-CV-1777-WSD (ND GA) (January 15, 2016), suggests a new era in international tax enforcement.  The opinion discusses the Internal Revenue Service’s (“IRS”) effort to collect Danish taxes pursuant to the Convention for the Avoidance of Double Taxation … Continue reading Uncle Sam Collects Danish Taxes-The World is Becoming a Smaller Place By Steven Toscher and Robert Horwitz

Read More

AGOSTINO & ASSOCIATES NEWSLETTER – EVALUATING COLLECTION ALTERNATIVES

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 January Newsletter – http://files.ctctcdn.com/f7d16a55201/11d1f7e4-92e8-45c9-bcf0-a1c696aa823a.pdf EVALUATING COLLECTION ALTERNATIVES: WHETHER TO FILE FOR BANKRUPTCY OR REQUEST AN OFFER IN COMPROMISE by By Frank Agostino, … Continue reading AGOSTINO & ASSOCIATES NEWSLETTER – EVALUATING COLLECTION ALTERNATIVES

Read More

THE TAX COURT ISSUES A REMINDER THAT YOU CANNOT COMPROMISE CRIMINAL TAX RESTITUTION by Robert S. Horwitz

In most cases in which a person pleads guilty to a tax-related crime in federal district court, the U.S. Attorney’s Office will require him to agree that the district court can order the payment of restitution to the IRS for the years for which he pleads guilty plus any years constituting relevant conduct. Following conviction … Continue reading THE TAX COURT ISSUES A REMINDER THAT YOU CANNOT COMPROMISE CRIMINAL TAX RESTITUTION by Robert S. Horwitz

Read More

It’s the Holidays – Say “Thank you” to Santa IRS-CI. By Robert S. Horwitz

The IRS recently gave unexpected Chanukah and Christmas presents to tax cheats and other assorted ne’er do wells. The present came from an unexpected source, Criminal Investigation (CI), in the form of CI’s 2015 Annual Report, released at the beginning of December, in time for holiday shopping. All you need to know about the current … Continue reading It’s the Holidays – Say “Thank you” to Santa IRS-CI. By Robert S. Horwitz

Read More

No Contest Clause Did Not Defeat Annual Exclusion Gifts by Krista Hartwell

Section 2503(b) of the Internal Revenue Code provides the annual exclusion, which excludes from taxable gifts the first $10,000 (adjusted for inflation) of “present interest” gifts. The current annual exclusion amount is $14,000. Crummey v. Comm’r, 397 F.2d 82 (9th Cir. 1968) supplies the rule for present interest gifts in trust. In order to have … Continue reading No Contest Clause Did Not Defeat Annual Exclusion Gifts by Krista Hartwell

Read More