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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 […] Read More…

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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. […] Read More…

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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 […] Read More…

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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 […] Read More…

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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 […] Read More…

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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 […] Read More…

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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 – https://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, […] Read More…

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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 […] Read More…

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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 […] Read More…

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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 […] Read More…

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Section 481: What Is a Change in Accounting Method and What Is Not? by LACEY STRACHAN

Section 481 provides that where a taxpayer’s taxable income for a tax year is computed under a method of accounting different from that previously used, an adjustment will be made to prevent amounts from being duplicated or omitted solely by reason of the change in accounting method.[i]  Section 481 applies regardless of whether the change […] Read More…

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If you don’t pay your taxes, you not be able to travel by ROBERT S. HORWITZ

Thinking of vacationing outside the United States when you owe the IRS money?  Think again. Congress recently enacted Fixing America’s Surface Transportation (“FAST”) Act, which President Obama signed into law on December 4.  Section 32101 of the Act (which is almost 500 pages in length) adds sec. 7345 to the Internal Revenue Code.  It is […] Read More…

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