Audit Representation

21
Jan

Employers Have Additional Time to Withhold Deferred Social Security Taxes from 2020

By:  Michael J. Tedesco The IRS released Notice 2021-11 on January 19, 2021 addressing how employers who elected to defer certain employees’ Social Security taxes (“Applicable Taxes”) can withhold and pay those taxes throughout the 2021 calendar year. On August 8, 2020, President Trump issued a Memorandum directing the Treasury Secretary to use his authority under I.R.C. Section 7508A, which

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22
Dec

Finally Some Good News! — Congress Locks In Full PPP Deductibility

By:  Randall P. Andreozzi Congress last night passed COVID-relief legislation that included a much-anticipated provision that allows businesses to deduct qualifying expenses paid with forgiven Paycheck Protection Program (PPP) loans. IRS caused a stir earlier this year when it issued IRS Notice 2020-32 which told taxpayers that such otherwise-deductible expenses lose their character if they’re paid with forgiven PPP loans.  The

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15
Jul

IRS People First Initiative Ends Today – What happens now?

By:  Derek Wheeler Today, July 15th, the IRS’ People First Initiative will come to an end. Implemented at the end of March as COVID-19 began spreading throughout the United States and large parts of the country began to shutdown, the People First Initiative relieved taxpayers of many impending tax burdens. Filing deadlines were extended, installment payment agreements were suspended, and

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26
Jun

High Income Non-Filers Beware – Audits Are Coming

By:  Heather L. Marello and Kevin M. Murphy During a recent web conference, IRS Large Business and International Division Commissioner Douglas O’Donnell warned that IRS is gearing up to initiate hundreds of non-filer audits against high income individuals and those with related flow-through entities. The original announcement of this initiative came in July, 2019, when LB&I added high income non-filers

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3
Apr

IRS Warns Taxpayers About COVID-19 Scams Related to Economic Impact Payments

The IRS has issued a warning to taxpayers to be cautious about phishing scams pertaining to IRS payments during the COVID-19 pandemic.  These scams can lead to serious tax-related fraud and identity theft.  Taxpayers should be mindful of this if they receive any phone calls, emails, text messages, social media or website requests for money or personal information.  Taxpayers are

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2
Apr

Update on Recent IRS Actions During COVID-19

There have been a significant number of recent IRS updates that impact taxpayers from both a controversy and compliance perspective. While our focus is to always provide the absolute best tax controversy updates and counsel for our clients, the IRS is currently modifying many current compliance procedures in the wake of the pandemic that are important to pass on to

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25
Mar

Federal Income Tax Return Filing and Payment Relief

Last week, the Treasury Department and the Internal Revenue Service (IRS) announced that the filing deadline for certain returns has been extended from April 15, 2020 to July 15, 2020 (Notice 2020-18) and they also provided some payment relief in response to the COVID-19 national emergency.  Although this is an ever-evolving and fluid situation, for the time being the Treasury

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20
Mar

State and Federal Tax filing deadlines extended to July 15th

Treasury Secretary announced today that the IRS’ tax filing deadline has been extended to July 15th.  This will be welcome news to not only taxpayers but the tax practitioners who were under the gun to get tax returns filed by April 15th in this tumultuous and uncertain environment resulting from the coronavirus outbreak.   With this new change, both the tax

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20
Mar

New York State Announces Penalty and Interest Waiver for Sales Tax Filings

As the COVID-19 spreads, taxpayers of all walks of life are affected by the vast actions taken to contain its spread and protect public health. In the face of this public health crisis, we want to ensure that all those that are being affected by this are educated on their rights and responsibilities in regard to their personal and business

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11
Feb

Recent Tax Court rulings may allow refunds of previously assessed penalties

By: Derek B. Wheeler, Esq. and Heather L. Marello, Esq. As part of the Restructuring and Reform Act of 1998 (“RRA 98”), Congress enacted IRC §6751(b)(1), which requires written supervisory approval for certain penalties proposed by the IRS.  Much of RRA 98 focused on legislative controls to prevent abusive practices by IRS personnel which had come to light in the

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