Last Filed Rule Overruled? IRS Collections Uncertain

Taxpayers will often file tax returns that do not report all of their allowable deductions and credits, with the intent of going back and filing amended returns once they are able to determine the correct deductions and credits.  Can the IRS base its collection analysis on the originally-filed but incorrect tax returns?  The court recently…

IRS Cannot Collect Taxes Discharged in Bankruptcy

In Internal Revenue Service v. Murphy, No. 17-1601 (1st Cir. 2018), the taxpayer discharged his unpaid taxes in bankruptcy.  The IRS continued to try to collect the discharged tax debt.  The case is a must read for taxpayers who find themselves in this same situation. The Facts & Procedural History The taxpayer in Murphy filed Chapter…

Deducting Mileage for Business With Minimal Activities

Can you deduct car and truck expenses, such as mileage, if your business has minimal activities?  The court addressed this in Samadi v. Commissioner, T.C. Summary Opinion 2018-27, which provides an opportunity to consider the question. Facts and Procedural History The facts and procedural history for the case are not unusual.  The taxpayer obtained a real…

Can the IRS Take Property Purchased in a Business Name?

If you owe the IRS back taxes but want to buy real estate or some other type of property, can you form a legal entity and use it to acquire property and thereby put the property beyond the IRS’s reach? The court recently addressed this in United States v. Jones, No. 8:17-cv-2389-T-24 AEP (M.D. Fla.…

Managing IRS Debts With Retirement Account Assets

Retirement accounts can present a number of challenges when trying to resolve an IRS debt. The IRS considers a retirement account as an asset in its collection analysis. The recent Scanlon v. Commissioner, T.C. Memo. 2018-51, court case provides an opportunity to consider the impact of retirement assets on IRS collection matters. The Facts &…

About the IRS Certificate of Discharge

The IRS’s lien for unpaid taxes attaches to all property owned by the individual. This can prevent the individual from selling or transferring their property or refinancing the property. There are several potential remedies that can help in this situation. One of these remedies is the IRS certificate of discharge. The IRS Certificate of Discharge…