Recent Posts in Articles by Mr. Haynes Category
Commingling Business Expenses
A recent decision by the Tax Court should serve as a warning to people that own multiple businesses but don’t always “respect the corporate formalities” associated with each business …Continue reading “Commingling Business Expenses” »
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DEALING WITH TAX DEBTS IN BANKRUPTCY AFTER THE BAPCPA
The intended beneficiaries of the humorously titled “Bankruptcy Abuse Prevention and Consumer Protection Act of 2005″ (BAPCPA) were the big banks and credit card companies — lobbying …
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TAX FRAUD INVESTIGATIONS – A PROCEDURAL ROADMAP Part II
I. Introduction In the last issue of the Corporate Criminal Liability Reporter, Spring 1988, we described the process involved in IRS criminal investigations — how they begin, the cast of …
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TAX FRAUD INVESTIGATIONS – A PROCEDURAL ROADMAP Part I
I. Introduction An IRS fraud investigation is a harrowing experience, not only for the corporate officers, directors and employees who are the subject of the investigation, but for the …
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VOLUNTARY DISCLOSURE OF OFFSHORE ACCOUNTS
Things are getting ever more uncomfortable for U.S. taxpayers holding undisclosed offshore bank and investment accounts. And in the wake of the very public fight between the Internal Revenue Service …
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OFFERS IN COMPROMISE AFTER TIPRA
After the Bankruptcy Abuse Prevention and Consumer Protection Act you thought it couldn’t get any worse for your tax delinquent clients? Wrong again. The latest Congressional gift to the IRS …
“PART PAY” INSTALLMENT AGREEMENTS
The continuing hostility of the IRS bureaucracy toward offers in compromise, and the recent decision of the Congress to severely restrict the availability and usefulness of bankruptcy, may …
NEGOTIATING INSTALLMENT AGREEMENTS
Written for the Maryland Society of Accountants One of the tasks most frequently faced in representing clients before the IRS Collection Division is negotiating an “installment agreement” …
NEGOTIATING OFFERS IN COMPROMISE
The last article in this series on dealing with the Collection Division addressed Installment Agreements — arrangements through which tax debts can be resolved by means of monthly payments. Some …
TARA REVISITED – THE NEW “INNOCENT SPOUSE ” RULES
Scarlett: But Rhett darling, our Separation Agreement requires you to pay any taxes resulting from the IRS audit that was going on during our divorce. Now Revenue Officer Sherman has levied my wages …
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THE NEW “INNOCENT SPOUSE ” RULES
Scarlett: But Rhett darling, our Separation Agreement requires you to pay any taxes resulting from the IRS audit that was going on during our divorce. Now Revenue Officer Sherman has levied my wages …
FEDERAL TAX LIENS – Part I
The federal tax lien is at the heart of all enforced collection action taken by the IRS Collection Division. Accordingly, representing clients requires an understanding of how the lien arises, the …
FEDERAL TAX LIENS – Part II
This is the second part of a two-part article about the federal tax lien. The last article covered the nature of the lien, focusing primarily on its broad reach, attaching as it does to “all …
THE STATUTE OF LIMITATIONS ON COLLECTION
For those beleaguered souls for whom nothing else works, the only hope of relief from unmanageable federal tax debts may be the statute of limitations on collection. In theory, the IRS has only 10 …
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HEALING SELF-INFLICTED WOUNDS – REPRESENTING NONFILERS
Never do today what you can put off until tomorrow. . . All of us procrastinate. But some take things to dangerous extremes — putting off the filing of tax returns for a few years, or even many …
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THE TRUST FUND RECOVERY PENALTY
The road to Hell, so we’re told, is paved with good intentions. And on the road to Hell, failure to pay employment taxes is definitely the fast lane. The resulting “trust fund recovery …
ENHANCED OPPORTUNITIES TO APPEAL COLLECTION ACTIONS
As all of us who represent taxpayers before the IRS Collection Division know only too well, the Revenue Officer handling a particular client’s case may not agree with our ever so reasonable …
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THE EXPANDING REACH OF THE FEDERAL TAX COLLECTOR – THE CRAFT AND DRYE DECISIONS
Nothing in life is certain but death and taxes, and never more so than now. The reason is that two recent Supreme Court decisions expand the reach of the federal tax collector, and some assets which …
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TAX COLLECTION PROBLEMS OF MILITARY PERSONNEL
Many people with tax collection problems feel like they’re in a combat zone, besieged by battalions of battle-hardened IRS Revenue Officers. But many tax practitioners, particularly those of us …
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TREATMENT OF PENSION BENEFITS AND RETIREMENT ASSETS
Knowing how the IRS Collection Division treats pension benefits and retirement savings is an important part of understanding a client’s situation and helping the client plan a course of action …
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LETTER REGARDING THE IRS ANNOUNCING A 3-WEEK EXTENSION OF THE OFFSHORE ACCOUNT VOLUNTARY DISCLOSURE PROGRAM
The IRS today announced a very brief extension of the current initiative aimed at facilitating the disclosure of previously hidden offshore accounts. The settlement program was due to expire on …
NEGOTIATING INSTALLMENT AGREEMENTS WITH THE IRS COLLECTION DIVISION
A task frequently faced in representing clients before the IRS Collection Division is negotiating an “installment agreement” — an arrangement under which monthly payments are made, …
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