Using an Offer in Compromise
In these economic times, more taxpayers are not able to fully pay their federal income taxes when due. There are several methods that may be used to pay tax liabilities in this situation, one of which is an offer in compromise
Published on July 01, 2010
Restricted Interest and Common Errors Made by the IRS
The Internal Revenue Code allows the IRS to charge interest when a taxpayer does not pay all required taxes by the due date of the return. The Code also requires the IRS to pay interest on refunds in certain circumstances. This item discusses the many nuances related to...
Published on July 01, 2011
2010 Estate Tax Payment and Carryover Basis Election Extended
Executors of estates of most decedents who died in 2010 can now get an automatic extension until March 19, 2012, to pay any estate tax due as well as to file an estate tax return, the IRS announced on September 13
Published on November 01, 2011
Determining the Taxability of S Corporation Distributions Part I
This two-part article provides a comprehensive review of the rules for determining the taxability of an S corporation’s distributions to its recipient shareholders. Part I provides an overview of the intent of Sec. 1368 and the related regulations, the shareholder- and corporate-level attributes that drive a distribution’s taxability, and the
Published on January 01, 2014
Installment Agreements An Alternative to Offers in Compromise
...The IRS expects income taxes to be paid in a timely manner, but a taxpayer may be unable to make full payment of a tax liability when it is due. While offers in compromise are extremely complex and are often rejected by the Ser
Published on October 01, 2007
New York Court of Appeals Upholds Amazon Law
New York’s highest court has confirmed that New York residents have to pay sales tax on internet sales where the vendor’s only contact with the state is through in-state affiliates
Published on June 01, 2013
Decision Not to Reinstate Offer Upheld
The Tax Court held that an IRS Appeals officer’s decision in a collection due process hearing not to reinstate a taxpayer’s offer in compromise after the taxpayer failed to meet a condition of the offer in compromise was not an abuse of...
Published on March 01, 2009
IRS Announces Changes to Lien Process
The IRS has announced a set of new policies designed to help taxpayers pay their back taxes and avoid liens. It also announced that it is making it easier for taxpayers to enter into an installment agreement and is expanding its streamlined offer...
Published on May 01, 2011
Day-Trading Losses Are Dissipation of Assets
The Tax Court held that a taxpayer’s losses from a period of day-trading activity constituted a dissipation of assets that the IRS could take into account in determining whether to accept the taxpayer’s offer in compromise.
Published on May 01, 2011
Tax Court Again Holds That Innocent Spouse Relief Limit Is Invalid
Despite being overruled by the Seventh Circuit in an earlier case, the Tax Court has again held that the regulatory two-year limitation period for filing a claim for equitable innocent spouse relief under Sec. 6015(f) is invalid. This item assesses the Tax Court's arguments in Hall, 135 T.C. No. 9
Published on November 01, 2010