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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
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
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
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
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
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
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