Innocent Spouse Litigation
As a result of the decades of prior government experience members of our firm possess, including employment in the IRS Audit Division, as well as IRS Counsel’s Office, Andreozzi Bluestein LLP is extremely well versed in how to best deal with an IRS audit.
Innocent Spouse Litigation
As a result of the decades of prior government experience members of our firm possess, including employment in the IRS Audit Division, as well as IRS Counsel’s Office, Andreozzi Bluestein LLP is extremely well versed in how to best deal with an IRS audit.
Although many taxpayers enjoy significant tax benefits from filing joint returns, these benefits can be outweighed by the exposure to joint and several liability where a tax deficiency or unpaid balance exists. The IRS might also offset a current year joint refund to pay a separate obligation of one spouse. In 1998, the IRS provided expanded spousal relief for taxpayers who file joint returns. Three types of relief exist with the best option depending upon whether the tax liability arose as a deficiency or as a filed joint return with a balance due, and upon the current marital status of the parties. If you owe income taxes from an activity or income of a spouse and if you don’t believe you should be liable for payment of the tax, you may be eligible for relief. Call the attorneys at Andreozzi Bluestein LLP for a review and analysis of your potential options.
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Client Privilege – When you have it & when you don’t may surprise you.
By: Gary P. Bluestein Many accountants incorrectly assume that their communications with their tax clients are always privileged and confidential. Unfortunately, sometimes tax cases can cross over into potential criminal exposure ...
Read moreUnderstanding the IRS Collection Process (Part 4)
By: Margaret Fichtner This is the last entry in our 4-part series of understanding the lifecycle of a tax controversy. In Parts 1, 2 & 3 we discussed an overview of a controversy, understanding the audit process, and also the ...
Read moreIntroduction to IRS Appeals and the U.S. Tax Court (Part 3)
By: Michael J. Tedesco, Esq. Introduction to IRS Appeals IRS Appeals is a separate branch of the IRS, whose purpose is to resolve tax controversies between the IRS and taxpayers through an informal, administrative process, fairly ...
Read moreUnderstanding Audit, Issues and Strategies (Part 2)
By: Heather L. Marello, Esq. Types of Audits Pursuant to the IRS Data Book, during calendar year 2016, the IRS audited almost 1.1 million tax returns, or 0.5% of all returns filed. A representative never can (or should) predict ...
Read moreThe Lifecycle of a Tax Controversy (Part 1)
By: Michael J. Tedesco, Esq. We find that accountants and taxpayers are often unfamiliar with certain aspects of the typical tax controversy (i.e. how a tax matter moves through assessment, Tax Court/Appeals and Collections). We ...
Read moreWHY YOU SHOULD ALWAYS PAY YOUR PAYROLL TAXES: A PRIMER ON TRUST FUND RECOVERY PENALTIES (PART 1)
By: Kevin Murphy, Esq. PART ONE When we discuss potential liability for the Trust Fund Recovery Penalty (TFRP)- I.R.C. § 6672, we often find the need to explain how payroll taxes work. Many clients, some lawyers and ...
Read moreAndreozzi Bluestein Litigators Achieve Precedential Tax Court Victory for United States Virgin Islands Taxpayers
In a court-reviewed opinion published on January 29, 2018, the U.S. Tax Court in Coffey, et. al. v. Commissioner, 150 T.C. No. 4, found in favor of the taxpayers and dismissed the Internal Revenue Service’s Statutory Notices of ...
Read moreFBAR Penalties – The Government’s Coin-Flip Burden of Proof on Willfulness
By: Heather L. Marello, Esq. The Bank Secrecy Act of 1970, Pub. L. 91-507, 84 Stat 114 (Oct. 26, 1970), addressed the government’s desire to monitor the use of foreign bank accounts for illegal activities by authorizing the ...
Read moreWhat Tax Reform Could Mean For Your Clients
By: Michael J. Tedesco, Esq. On December 22nd, 2017 with one stroke of a pen, president Trump signed into law the most sweeping tax law changes in a generation. For the first time in over 30 years tax professionals will confront ...
Read moreAndreozzi Bluestein Attorneys Speak on Federal and State Compliance Issues
Buffalo Law Journal’s Michael Petro interviewed Andreozzi Bluestein’s Senior Associate Michael Tedesco and Associate Heather Schmidt on federal and state compliance issues for his Tax Law Special Report. Petro’s federal ...
Read moreWe are a law firm built on Experience, Vision & Trust
Whether you need tax counsel for litigation, representation before the IRS, an advocate in tax controversies, or thorough tax analysis and objective consulting, our attorneys have the experience and obtain lasting solutions.