- Practice Areas
- Professionals
- Blog & Events
- Contact
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
By: Heather Marello, Esq. In 2013, New York added Section 171-v to the tax law, which provides that the State may suspend a taxpayer’s driver’s license if his or her tax, penalty and interest exceeds $10,000 and the taxpayer is not in an installment payment arrangement or have an accepted Offer in Compromise by the Tax Department. When the law
By: Randall P. Andreozzi, Esq. Cryptocurrency investors be warned. The IRS is coming for you. Over the course of several years, the IRS has methodically ramped up its efforts to tackle the burgeoning cryptocurrency market. As taxpayers enter this market, it’s important that they understand that virtual currency transactions are taxable events involving actual assets and that the IRS treats
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
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,
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
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
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
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
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