Audit Representation


IRS Issues Important and Timely COVID Pandemic-Related Penalty Relief

By: Tiffany D. Bell, Esq. Businesses and individuals will receive automatic penalty relief for failure to file certain tax returns and international information returns for the 2019 and 2020 tax years.  IRS issued Notice 2022-36 on August 24, 2022, notifying taxpayers that the specified penalties will be waived, or if previously assessed, abated, refunded or credited. IRS announced the penalty

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Thinking of Leaving New York State? Preparation, Documentation and Intent are Keys to Avoiding Future New York Tax Bills.

By: Justin J. Andreozzi, Esq. In recent years, many high earning and wealthy New York residents have departed NY State to escape the ever-increasing burden of State and Local taxes. While the prospect of paying no State income tax is appealing, NY State has a strong incentive to review these moves to ensure that are indeed changes in domicile and

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Update on IRS Enforcement Trends

By: Kevin M. Murphy, Esq. We have all seen reports and studies lately regarding the “tax gap”, including one from the Treasury Inspector General for Tax Administration (TIGTA) describing millions lost to tax avoidance. These are usually followed by a statement from a member of Congress stating the urgent need to revise tax laws to collect more revenue from wealthy

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ACA Penalties Lurking for Unsuspecting Employers

By: Derek B. Wheeler, Esq. It has now been more than a decade since the Patient Protection and Affordable Care Act (ACA) was signed into law by President Obama. Among the many requirements the law placed on taxpayers was requiring many businesses to offer minimum essential coverage to its employees. While much has been made of the substantive requirements of

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Can We Discern Tax Opportunities From the Haze of the Crypto Horizon?

By: Randall P. Andreozzi, Esq. While we anxiously await Treasury Department guidance on cryptocurrency (See, TIGTA Report of September 24, 2020, “The Internal Revenue Service Can Improve Taxpayer Compliance for Virtual Currency Transactions”), events, good and bad, continue to arise that create tax planning and management opportunities for investors.  Take, for example, Bitcoin’s recent dive from its high of some

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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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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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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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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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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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