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IRS Bank & Wage Garnishments IRS Collections IRS Collections Tax Relief Articles

Making Voluntary Payments to the IRS


For those who owe the IRS back taxes, the decision as to how to pay the IRS raises a number of concerns.  One such concern for those who owe taxes for several different tax years or several different types of taxes, is what year and tax account the payments are applied to.  Typically taxpayers get […]

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Criminal Tax Tax Relief Articles

Sentence Enhancements in Criminal Tax Cases


The federal sentencing guidelines help the courts set criminal sentences. These guidelines have to be considered when deciding whether to accept a plea agreement and how to handle the trial. The recent United States v. Kushimo, No. 18-3222 (3d. Cir. 2019), case provides an opportunity to consider two of the sentencing enhancements that often apply […]

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Reduce Taxes Tax Relief Articles

Is IRS Bound by Social Security Disability Determination?


If the Social Security Administration determines that you are disabled, does the IRS have to accept that determination for tax purposes? It is one government is it not? The court considered this in Gentry v. United States, No. 3:18-cv-00581 (D. Nev. 2019) for the disability exception allowing for a longer period of time to file […]

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Criminal Tax Tax Relief Articles

Arguing that the Tax Return You Filed is Incorrect


If your tax return is incorrect and you have pending tax litigation with the IRS, can you argue that the tax return is incorrect? What if the time period for filing an amended tax return is still open? Should the court consider the new argument or should it rely on the incorrect tax return? The […]

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IRS Whistleblower Tax Relief Articles

Whistleblower’s Claim Limited by IRS’s Discretion Not to Collect Tax


If you turn in a tax cheat by filing a whistleblower claim with the IRS, what happens if the IRS does not realize the importance of the information received? Put another way, what if the IRS leaves money on the table by failing to assess the full amount for the taxpayer? Is the whistleblower entitled […]

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IRS Collections IRS Levies & Liens Tax Relief Articles

Can the IRS Reach Assets in Land Trusts?


Can the IRS reach an interest in real property held in a land trust? If so, what happens if the taxpayer sells the property? Can the IRS recoup the land from the new buyer or is the IRS limited to the proceeds received? The court addresses this in United States v. Harold, No. 2:18-cv-10223 (S.D. […]

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Criminal Tax Tax Relief Articles

Using Multiple PTINs to File Fraudulent Tax Returns


It can be difficult to be a tax preparer. The rules change just about every year. The IRS has increased its focus on identifying and punishing tax return preparers. This includes criminal sanctions for the tax return preparers. The enforcement actions often do not factor in the realities of the tax preparation business. The recent […]

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Tax Penalties Tax Relief Articles

Does Late Payment Tax Penalty Run from Extended Due Date?


If you file an extension for an estate tax return and pay the tax before the extended due date, can the IRS impose penalties for late payment? The court addresses this in Estate of Agnes R. Skeba v. United States, No. 3:17-cv-10231 (D.N.J. 2019). Facts & Procedural History The taxpayer is an estate. It’s estate […]

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Criminal Tax Tax Relief Articles

The Affirmative Act of Tax Evasion


Taxpayers get behind on their taxes as they do every other type of liability. It happens. But owing the IRS unpaid taxes can be more than a civil problem. Non-payment can lead to criminal tax evasion charges. The United States v. Connerton, No. 3:17-cr-47 (D. Conn. 2019), case provides an opportunity to consider the “affirmative […]

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IRS Collections IRS Collections Tax Relief Articles

Can the IRS Foreclose on an Inheritance that is Jointly Owned?


What happens when someone inherits money from their parents, but they also owe the IRS? Can the IRS collect on the inherited assets? What if the taxpayer only inherited a fractional interest in the property? Can the IRS foreclose on the property to pay the back taxes? The court considered this in United States v. […]