10
Jan

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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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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13
Jun

IRS Completes Unprecedented Campaign Targeting Employment Tax Crimes

By: Kevin Murphy, Esq. In our most recent blog post, we discussed the importance of timely payment of payroll taxes and how serious the IRS is taking the issue of criminalizing the Trust Fund Recovery Penalty. As a follow up, we wanted to pass along a recent news release from the IRS that highlights the conclusion of an unprecedented two

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31
May

WHY YOU SHOULD ALWAYS PAY YOUR PAYROLL TAXES: A PRIMER ON TRUST FUND RECOVERY PENALTIES (PART 2)-CRIMINAL EXPOSURE

By: Kevin Murphy, Esq. In Part 1, of this blog, we explained and discussed the civil aspects of IRC 6672- the Trust Fund Recovery Penalty (TFRP). At the end of Part 1, we mentioned that the civil statute is virtually identical to the criminal statute. The two statutes are highlighted below: Section – IRC 6672 (Civil) Any person required to collect,

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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.  Everyone has heard of and paid payroll taxes, but that doesn’t mean they grasp the mechanics of how it works. An employer must pay federal payroll taxes on

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5
Oct

Taxpayer Representation SUPER CONFERENCE (October 5-7, 2017)

WHEN:  October 5-7, 2017 WHERE: Las Vegas, NV Kevin Murphy Presenting Topic: Officers, Officers, Officers Dealing with Tax Compliance Officers (Office Auditors), responding to Revenue Officers, handling Appeals Officers, and negotiating with Settlement Officers, it’s what we do. Day in, and day out. Building on 20+ years of experience on the dark side, Kevin will offer insights, tips, and techniques for dealing with the various IRS

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