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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 ...

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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 ...

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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 ...

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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 ...

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IRS Flaunts Recent Tax Court Victory in Microcaptive Arena

By: Heather L. Marello, Esq. In a recent press release, IRS is again urging participants in abusive microcaptive insurance arrangements to cease participation in such transactions.  This message ...

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The Tax Court Reminds Foreign Corporations of the Disastrous Consequences of Failing to File Forms 1120-F U.S. Income Tax Returns

By: Heather L. Marello, Esq. I.R.C. § 6012(a)(2) imposes an income tax return filing requirement on “every corporation subject to taxation under subtitle A.”  The Treasury Regulations clarify ...

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Bankruptcy Related Changes Under the CARES Act and the Consolidated Appropriations Act of 2021

By: Daniel F. Brown, Esq. The Consolidated Appropriations Act of 2021 The Consolidated Appropriations Act of 2021 (the “Appropriations Act”) was passed by Congress and became law on December ...

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Virtual Currency Coming to an FBAR Near You

By:  Michael J. Tedesco With the rapid rise of virtual currency, the IRS and Financial Crimes Enforcement Network (FinCEN) were required to make quick decisions on interpretations of how these ...

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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 ...

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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 ...

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Subchapter V Bankruptcy – A potential lifeline for struggling small businesses

By:  Gary P. Bluestein The financial consequences of COVID-19 have been particularly difficult for a large number of American small businesses and with lockdowns accelerating in many states, many of ...

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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 ...

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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 ...

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Debt, Bankruptcy and COVID-19

By: Ruth R. Wiseman, Esq. and Melissa A. Brennan On March 27, 2020, the President signed the Coronavirus Aid, Relief, and Economic Security Act (“CARES”) Act. The act has created numerous ...

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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 ...

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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 ...

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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 ...

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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 ...

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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 ...

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Tax Court Trial Sessions Cancelled

On March 13, 2020 the United States Tax Court determined that, due to the current health crisis, the Tax Court buildings will be closed effective immediately.  Previously scheduled Tax Court trial ...

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Optional 90 Day Extension on IRS Payments

The Trump Administration announced its new economic stimulus plan today which includes an option for taxpayers to delay their tax payments for 90 days.  The plan allows deferrals of up to $1 million ...

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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 ...

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New York Adds an Economic Hardship Exception to License Suspension Statute

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 ...

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IRS Captive Insurance Global Settlement Offer- Know your options.

By: Randall P. Andreozzi, Esq. In 2016 the IRS issued Notice 2016-66, which identifies certain micro captive insurance transactions as potentially abusive.  The Notice generally describes the ...

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Our View on Cryptocurrency Taxes & the IRS

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 ...

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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 ...

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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 ...

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“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 ...

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Voluntary Disclosure options for taxpayers after the closing of the OVDP

By: Tiffany D. Bell When the IRS closed the 2014 OVDP last fall, which had provided an avenue for taxpayers to come into compliance with any past offshore tax and information reporting, it left many ...

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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 ...

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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 ...

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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 ...

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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, ...

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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 ...

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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 ...

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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 ...

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WHY YOU NEED ESTATE PLANNING

By: Ruth Wiseman, Esq. We all know the old saying that there are only two certainties in life – Death and Taxes. While this is an unfortunate truth, the good news is that with the right planning ...

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Planning to file a Delinquent 1120F Return? Make sure you know the Risks.

By: Lou Carlow On February 1, 2018 the Commissioner of Internal Revenue, Large Business and International Division (LB&I) issued a memorandum providing guidelines for handling delinquent Forms ...

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TAKE NOTICE!

By: Royston Mendonza, Esq. The IRS has a repository of hundreds of notices that it issues to Taxpayers for a variety of issues. In fact, a statement of IRS notice codes released in 2002 is 120 pages ...

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Are 2018 State and Local Real Property Taxes Paid in 2017 deductible or not? The Answer’s in the Statute.

By: John L. Marien On December 22, 2017, President Trump signed into law the Tax Cuts and Jobs Act.  In light of the various tax cuts contained in the revisions to the Internal Revenue Code, ...

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Recent Tax Court Ruling Limits Statute of Limitations for Foreign Account Reporting

By: Tiffany D. Bell, Esq. In 2010, Congress added to the anxiety of tax practitioners when it expanded the statute of limitations for the IRS to assess income taxes to six years when a taxpayer fails ...

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IRS Offshore Voluntary Disclosure Program Will End on September 28, 2018

By: Randall P. Andreozzi, Esq. The IRS announced on Wednesday that it will officially end the 2014 Offshore Voluntary Disclosure Program (affectionately known to practitioners as the “OVDP”) on ...

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Partner Gary Bluestein Receives Community Playmaker Award

We are proud to announce that our partner, Gary Bluestein, has received the Walmart Community Playmaker Award.  He received this award in honor of his efforts to help the local community, including ...

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Can you discharge your tax debt through Bankruptcy?

By: Gary P. Bluestein, Esq. The general view of most accountants and attorneys we talk to is that tax debt is not dischargeable in Bankruptcy. When we tell them that a tax debt may indeed be ...

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Andreozzi Bluestein LLP Promotes Justin J. Andreozzi to Senior Associate

We are proud to announce the promotion of attorney Justin J. Andreozzi from Associate to Senior Associate.  Mr. Andreozzi is admitted to practice in the State of New York Appellate Division- Fourth ...

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Andreozzi Bluestein LLP Promotes Heather L. Marello to Senior Associate

We are proud to announce the promotion of attorney Heather L. Marello from Associate to Senior Associate.  Mrs. Marello focuses her practice on tax controversy and international tax compliance, and ...

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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 ...

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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 ...

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What Tax Reform Could Mean For Your Clients

By: Michael J. Tedesco, Esq. On December 22nd, 2017 with one stroke of a pen, president Trump signed into law the most sweeping tax law changes in a generation. For the first time in over 30 years ...

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IRS Relaxes Bona Fide Residency Rules in the Wake of Hurricanes Irma and Maria

By: Heather L. Marello, Esq. In the wake of recent hurricanes that devastated Puerto Rico and the U.S. Virgin Islands, IRS released Notice 2017-56, Physical Presence of Certain Individuals in the ...

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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, ...

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Andreozzi Bluestein Named One of Buffalo’s Healthiest Employers Once Again

Andreozzi Bluestein has been named one of Buffalo’s Healthiest Employers once again.  The honorees were celebrated at a healthy luncheon and expo held on May 25th at the Buffalo Niagara ...

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The Tax Alliance Conference (June 6-8, 2017)

WHEN:  June 6-8, 2017 WHERE: Plano Centre, Dallas Texas Gary Bluestein Presenting Topic: Trust Fund Recovery Penalty vs. Criminal Charges Under Section 7202 To Register Visit: ...

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NACBA Annual Convention (May 4-7, 2017)

WHEN:  May 4-7, 2017 WHERE: Walt Disney World’s Dolphin Hotel   Gary Bluestein Presenting Topics: Discharging Taxes in Bankruptcy Advanced: Know the Code, Nuances & Strategies of taxes ...

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Tax Issues for Non-Tax Attorneys (CLE Seminar May 25, 2017)

WHEN:  May 25, 2017 WHERE: The Jackson Center, Jamestown NY 14701 Registration Begins 8:30am Program 9:00am-12:00pm Lunch will be provided Attorneys will receive complimentary CLE Credits To ...

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In’s and Outs of Audit and Collection for Accountants (CPE Seminar May 11, 2017)

WHEN:  May 11, 2017 WHERE: Hampton Inn & Suites, Jamestown NY 14701 Registration Begins 8:30am Program 9:00am-11:00am CPAs will receive two complimentary CPE Credits To register for this event, ...

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IRS Delinquent 1120F Campaign – Are You Prepared?

By: Lou Carlow The IRS has identified the failure to file Forms 1120-F as the most recent front for its enhanced campaign to enforce compliance.  This campaign sends a clear message to foreign ...

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Thank You To All Who Attended Our Ribbon Cutting Ceremony!

We would like to thank all of our friends and colleagues for attending our Ribbon Cutting Ceremony.  We are very excited to see what the future holds! Please take a moment to read the Buffalo Law ...

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How U.S. Foreign Information Reporting applies to Your Cross Border Holdings

By: Michael J. Tedesco As another filing season is upon us, it is important to be aware of the extensive information reporting associated with holding assets outside of the U.S.  Failing to file ...

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Andreozzi Bluestein CFO Speaks on merger and growth

Buffalo Law Journal’s Michael Petro interviewed Andreozzi Bluestein’s CFO, Laura Benedetti, on the growth and expansion of the firm. The full text of Michael Petro’s article, “Following ...

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Andreozzi Bluestein Attorneys Speak on Federal and State Compliance Issues

Buffalo Law Journal’s Michael Petro interviewed Andreozzi Bluestein’s Senior Associate Michael Tedesco and Associate Heather Schmidt on federal and state compliance issues for his Tax Law Special ...

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The Threat of Parallel Investigations: When Civil Isn’t Civil

By: Justin J. Andreozzi, J.D.; Randall P. Andreozzi, J.D.; and Arlene Hibschweiler, MBA, J.D. While at one time, the IRS would discontinue a civil examination when it began a criminal investigation ...

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Law Creates New Due Dates for FBAR and Other Tax and Informational Returns

By: Heather Schmidt On Friday, July 31, 2015, President Obama signed H.R. 3236, the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 into law.  In addition to ...

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Andreozzi Bluestein LLP Receives Award from Volunteer Lawyers Project for Pro Bono Work

The Volunteer Lawyers Project (VLP) for Erie County selected Andreozzi Bluestein LLP as recipient of the 2014 Law Firm Commitment Award. VLP presented the award at the “Champions for Justice ...

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Taxpayer Advocate Service Criticizes IRS’s Offshore Voluntary Disclosure Programs in 2014 Congressional Report

By: Heather L. Schmidt To combat money laundering and evasion of U.S. income obligations through the use of offshore accounts, Congress imposed a requirement on all United States taxpayers to ...

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Federal Court Approves U.S. Government Issuance Of John Doe Summonses

By: Michael J. Tedesco A Federal Judge recently approved the Internal Revenue Service’s issuance of what is known as a “John Doe” summons¹ to several entities in the U.S who utilized the ...

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Jacqueline Schneegold is Promoted to Senior Paralegal

We are pleased to announce the promotion of Jacqueline A. Schneegold to Senior Paralegal. Mrs. Schneegold has been with the firm since July 2004.  She assists in the practice areas of audit ...

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Recent Revisions to the IRS Offshore Voluntary Disclosure Programs

By: Randall P. Andreozzi Recent revisions to the IRS Offshore Voluntary Disclosure Programs illustrate that the Service is becoming more aggressive and less tolerant with those taxpayers who have not ...

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Matrimonial Law and the IRS

By: Gary Bluestein, Esq. Federal tax law can impact virtually every area of legal practice.  For example, in debtor/credit law, certain property is protected from enforced collection, such as a ...

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IRS Makes Significant Changes to the Offshore Voluntary Disclosure Program and Streamlined Voluntary Disclosure Program

By: Michael J. Tedesco On June 18, 2014, the Internal Revenue Service (“IRS”) announced significant changes to the offshore voluntary disclosure programs. As part of the announcement, the IRS has ...

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Tiffany Bell is Promoted to Senior Associate

We are pleased to announce the promotion of attorney Tiffany D. Bell from Associate Attorney to Senior Associate. Mrs. Bell is a graduate of the University at Buffalo Law School. She is admitted to ...

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Michael Tedesco is Promoted to Senior Associate

We are pleased to announce the promotion of attorney Michael J. Tedesco from Associate Attorney to Senior Associate. Mr. Tedesco is admitted to practice in New York State, the United States Virgin ...

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Aragona Trust: Passive Activity Losses, the Material Participation Exception, and the Medicare Tax

Generally speaking, most taxpayers, including individuals and trusts, are denied the use of their passive activity losses and credits to offset ordinary income under the passive activity loss ...

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Tax Anxiety – Good News & Bad News

With the upcoming hype surrounding taxes as April 15th approaches, anxiety increases for those in tax trouble. A significant number of people have been contacted by the taxing authorities about ...

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The 11th Circuit Court of Appeals Reverses Tax Court Ruling on Intervention in USVI Cases

On February 20, 2014, the United States Court of Appeals for the Eleventh Circuit released an opinion allowing the Government of the United States Virgin Islands (“USVI”) to intervene in three ...

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John Marien of Andreozzi Bluestein LLP Named to Tax Notes Person of the Year List

John Marien of Andreozzi Bluestein LLP was named to the Tax Notes’ 2013 Person of the Year list.  Tax Analysts publishes an annual list of the individuals who have significantly influenced ...

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Department of Justice Reminds Swiss Banks That Time is Running Out to Participate in a Non-Prosecution Agreement

In a November 5, 2013 post in The Justice Blog, the United States Department of Justice (DOJ) Tax Division issued a reminder to Swiss Banks that their time is running out to enter into a ...

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Liens and Levies

By: Gregory D. Verdibello, Esq. Once a taxpayer’s liability has been formally recorded on the books and records of the Internal Revenue Service (“IRS”), the IRS may use one of its collection ...

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Offers in Compromise: A Guide

By: Royston Mendonza Overview Very simply, an Offer in Compromise (“Offer”) is where a Taxpayer “offers” a sum of money to the Internal Revenue Service (“IRS”) to “compromise” a tax ...

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There’s Always Something (the IRS) There to Remind Me

Dionne Warwick Bankruptcy Case Seeks to Discharge Taxes By: Daniel Brown “Wishin’ and Hopin’”[2] to discharge more than $10.2 million in taxes, Dionne Warwick filed a Chapter 7 personal ...

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The New York State Department of Taxation and Finance Grants Relief for Non-Filers

By: Gregory Verdibello Unfiled returns can create financial and emotional stress, and can cause criminal issues for many people. It seems that more and more people are failing to file their returns ...

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Shedding Some Light on the PFIC Regime

By: Kenneth A. Grossberg Today, United States investors in foreign corporations often find themselves with an unknown or unexpected problem.  In particular, investors in mutual funds organized ...

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Federal Court Authorizes IRS to Issue “John Doe” Summons to UBS

The Internal Revenue Service (IRS) and the U.S. Department of Justice (DOJ) continue to actively seek information about U.S. taxpayers with interests in foreign accounts.  The IRS and the DOJ sought ...

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Andreozzi Bluestein LLP Partners Named to New York State Super Lawyers

August 2012, Buffalo, NY– All five partners of Andreozzi Bluestein LLP have been named to the New York State Super Lawyers list as five of the top attorneys in New York State for 2012. No more ...

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Internal Revenue Service Offers New Guidance on FBAR and OVDP Procedures

The IRS has announced new procedures to aid voluntary disclosures by taxpayers with undisclosed foreign accounts. The new procedures follow the IRS’ January 9, 2012 announcement of the 2012 ...

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Randall Andreozzi Co-Authors Article on FBARS

Individuals with a financial interest in bank accounts or certain foreign financial accounts must report these accounts, if their cumulative value exceeds a threshold amount. Form TD F 90-22.1, ...

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We Have Merged Click Here to Find Out the Exciting Details

March 2012, Buffalo,NY– A merger between Buffalo‐based firms Andreozzi Fickess LLP and Bluestein & Weber P.C. has been announced effective March 5, 2012. The merged firm will practice ...

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HSBC Bank Accounts Targets by IRS Offshore Activity Efforts

On April 7, 2011, a United States District Court issued an order permitting the IRS to serve John Doe summonses requesting information from HSBC Bank regarding U.S. taxpayers who hold HSBC accounts ...

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IRS Launches Compliance Initiative on Estate & Gift Tax

The IRS has recently launched a compliance initiative aimed at identifying taxpayers with potential estate or gift tax liabilities or related compliance issues. As part of this initiative, the IRS ...

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IRS Offers New Voluntary Disclosure Program for Offshore Bank Account Holders

On February 8, 2011 IRS Commissioner Douglas Shulman announced a new voluntary disclosure program forU.S. taxpayers with offshore financial accounts. The Offshore Voluntary Disclosure Initiative ...

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WikiLeaks May Impact US Offshore Account Holders

The website, WikiLeaks, has become a controversial news phenomenon. WikiLeaks publishes secret, private, and classified information primarily with respect to government practices. Its recent ...

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President Obama Signs Small Business Act Providing Significant Tax Benefits

On September 27th President Obama signed the Small Business Jobs Act of 2010  into law. The Act contains several tax provisions that may prove beneficial to many small businesses and their owners. ...

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Government Plans to Subpoena Accountants Engaged in Kovel Arrangements

Attorneys are not always fluent in accounting.  Thus, accountants are often retained by a client’s attorney to assist them in rendering advice to the client.  In the seminal case United ...

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Foreign Bank Account Reporting FBAR and the IRS Voluntary Compliance Initiative of 2009

On March 23, the IRS announced its voluntary compliance initiative to encourage disclosure of foreign bank account details, such as previously undisclosed foreign financial accounts and entities. The ...

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