Audit Representation

1
Mar

“But It’s Not My Fault” How to Obtain Innocent Spouse Relief

By: Heather L. Marello Married taxpayers often file their annual income tax returns electing “married filing joint” status.  While often beneficial from a tax perspective, spouses rarely understand that, by electing this status, each spouse agrees to be liable for the entire amount due for that year – whether it is the liability reported as due on the return or

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22
Jan

Think the IRS is quiet during the Shutdown? Think Again! Another Form 3520 Trap for the Unwary

By: Randall P. Andreozzi Things are emerging from the abyss that is the longest government shutdown in United States history.   Yes, there exist some things so resilient, so pervasive, so constant they can survive and proliferate even in a governmental vacuum.  Our friends who are U. S. citizens living abroad know this species all too well and are likely collectively

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4
Jan

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 for a client, and not knowing the scope and limitations of privilege can be devastating, both to the practitioner and to the client.  Although there is limited privilege provided

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6
Dec

Understanding 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 appeals process. In this 4th and final entry we will discuss what happens after a taxpayer files their Tax Return

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27
Nov

Introduction 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 and impartially, without litigation. IRS Appeals has substantive experts in many of the same areas as the IRS (i.e. designated personnel who deal only

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13
Nov

Understanding 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 to a client whether his or her return will be selected for audit, as a number of factors can cause the

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7
Nov

The 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 have put together a series of articles moving through “The Lifecycle of a Tax Controversy”. What follows is the first part of what will be

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10
Sep

WHY 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 accountants and unfortunately even some IRS agents and Assistant U. S. Attorneys don’t really understand what constitutes a trust fund liability.  Everyone has

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31
Jan

Andreozzi 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 Deficiency against them as time barred. Andreozzi Bluestein LLP represented the Petitioners in this case before the Tax Court. The Petitioners claimed

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23
Jan

FBAR 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 Secretary of the Treasury to require U.S. citizens, residents, and others to “keep records, file reports, or keep records and file reports,

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