I Spy Tax Fraud! Do You?
The word “fraud” conjures up many images, none of which are positive. As Circular 230 tax professionals, we never knowingly jeopardize our credentials while serving clients. Ever cautious, we could, nevertheless, find ourselves representing a client who has engaged in fraudulent activity. Can you recognize the signs of tax fraud? How do you handle a client’s matter with potential or actual fraudulent transactions? According to the Interna... Alan L. Pinck, EA, Ann E. Kummer, EA, CPA
Is an Analysis of the Thought Process of the Approving Supervisor Required in a Case Involving a Trust Fund Recovery Penalty?
Under IRC §§6320 and 6330, taxpayers have the right to a collection due process (CDP) hearing, which provides them with an independent review by the IRS Office of Appeals of the decision to file a Notice of Federal Tax Lien or the IRS’s proposal to undertake a levy action. At the hearing, the taxpayer has a statutory right to raise any relevant issues related to the unpaid tax, lien, or proposed levy, including the appropriateness of ... Steven R. Diamond, CPA
Is IRS Ready to Implement Tax Reform?
While some of us are still recovering from our sunburns at the beach, many of us are looking at the shorter days and are beginning to worry if IRS has enough time to fully implement the Tax Cuts and Jobs Act (TCJA) in time for the 2019 filing season. Guidance, in the form of proposed regulations, notices, and forms and instructions, has certainly been helpful and much appreciated, but not having finalized these items is getting danger... Jeffery S. Trinca, JD
The IRS Revenue Officer: Friend or Foe?
It is likely you will encounter an IRS revenue officer who is difficult, unyielding, and possibly aggressive. You may perceive that the revenue officer's job is to make your and your client’s lives difficult. However, the truth is very different. Sure, a collection case making its way to a revenue officer is deemed serious by the IRS. After all, revenue officers are the IRS’s most experienced and sophisticated collection agents. Their foc... Howard S. Levy, JD
Overview of Practice Before the U.S. Tax Court
This article will focus on income tax deficiency and collection due process (CDP) jurisdiction, but the Tax Court also has jurisdiction over IRS’s denial or refusal to act on abatement of interest under IRC §6404 and innocent spouse cases under §6015; cases related to employment status; and denial of whistleblower claims, among others. The Tax Court was established to handle tax deficiency cases that require a timely filed notice of defic... Sherrill Trovato, EA, USTCP