• IRS Releases “Tax Tip” on Charitable Gifts

    The IRS has released a “Tax Tip” to remind taxpayers of the rules to be mindful of when making charitable gifts this holiday season. As many of us consider those less fortunate during the holiday season, many will choose to make contributions to charities. The end of the year is also a popular time for […]

  • 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 pays. The new law also helps those with alimony and child support awards. But a third winner was your friendly, neighborhood tax collector. In general, the BAPCPA makes […]

  • TAX FRAUD INVESTIGATIONS – A PROCEDURAL ROADMAP Part II

    *Read Part I here if you haven’t already*  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 players, the investigatory techniques used, and the manner in which evidence is summarized for subsequent use in reviewing […]

  • 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 corporation’s legal advisors as well. The process many begin innocuously with a routine civil tax examination, or with the jolting arrival of a grand jury subpoena. […]

  • 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 and Union Bank of Switzerland (UBS), it is quite possible that one of your clients will reveal to you that he has an offshore account […]

  • 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 Collection Division is Section 509 of the Tax Increase Prevention and Reconciliation Act of 2005 (TIPRA). One must at least give grudging credit to the […]

  • “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 combine to place more emphasis on installment agreements. But some taxpayers, particu­larly those with large tax debts involving multiple tax years, may find that they can’t meet […]

  • 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” — an arrangement under which the taxpayer makes monthly payments against the outstanding tax debt, free of the threat of levy and distraint action. Despite the Service’s imposition […]

  • 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 folks, however, owe so much that an installment agreement is not a practical solution. Interest and penalties can accrue so quickly that the liability actually […]

  • 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 and seized my horse and my last mint julep! Rhett: Frankly, my dear, I don’t give a damn. Sound familiar? Ever represent […]