Happenings Inside the IRS Under the New Administration

Last week in Denver, Colorado the IRS quietly paraded out some of their race horses to share what is happening under the new administration. With Steven Mnuchin‘s most recent confirmation as Treasury Secretary and Commissioner Koskinen’s days numbered, a sense of being rudderless was anticipated. Knowing that a hiring freeze and location consolidation are adversely impacting…

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What to do WHEN you disagree with the IRS

The IRS Office of Appeals offers taxpayers an opportunity to resolve their tax disputes without going to court. Appeals is an independent function within the IRS that provides an impartial review of your tax dispute. Appeals also offers mediation services through Fast Track Settlement and other programs. These mediation programs are designed to help you…

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Situations by which Docketed U.S. Tax Court Cases may be sent to Appeals for Settlement Consideration

In Notice 2015-72 the IRS proposes to update Rev. Proc. 87-24 regarding situations by which docketed U.S. Tax Court cases may be sent to Appeals for settlement consideration. This proposal: Intends to ensure that docketed cases are handled consistently nationwide. Clarifies that, except in rare circumstances, Counsel will refer cases docketed in Tax Court to Appeals for settlement consideration.…

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Marijuana Dispensary Income Tax Guidance Update: IRS Memo 201504011

As many of you know who follow my tax musings via this blog, I recently led a team of people that shepherded a Marijuana Dispensary through the IRS Examination and Appeals functions. The dispensary in question was owned and operated by a taxpayer who in all regards was a good, honest, hard working, caring, person…

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Odujinrin v. IRS Commissioner Reinforces the Significance of Engaging a Reputable Enrolled Agent

In Wole Odujinrin v. IRS Commissioner the petitioner, a hematology oncologist who represented himself, did not have adequate substantiation to support his petition and was not entitled to claim a net operating loss. He was also liable for an accuracy-related penalty under IRC 6662 – the expensive kick in the shorts. This petitioner moronically showed up with little…

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Denver IRS Practitioner Meeting July 2014 – A Summary Review with Excellent References for FBAR and FinCEN Matters

Meeting Summary as produced by IRS Senior Stakeholder Liaison Deborah Rodgers Nancy Carver, IRS Local Area Counsel Counsel continues to assist in training employees on partnership audits, and TEFRA. Counsel is also assisting in the investigations of promoters. Virtual currency is on the radar for Internal Revenue Service. Controlling ID Theft is a task that…

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Use IRS Form 8082 to Report An Incorrectly Issued K1

I’ve been working a very complicated file since my last post involving income in 11 states and countless K-1s, Partner’s Share of Income, Deductions, Credits, etc. Interestingly enough one of my trusted lieutenants noticed that one of the K-1s from one of the partnerships incorrectly reported a gain on the sale of a partnership asset as a…

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Decoding the IRS – Document 6209

Understanding what you are up against with the IRS can be frustrating on many levels. When it comes to the terminology they throw around, especially acronyms, what you will find is that even seasoned veterans quite often pull out specialty reference manuals or what I often refer to as code books.  This post is intended…

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Top 8 Free US Tax Research Sites

The best free US tax research sites in my opinion are: 1. For actually referencing the US Tax Code – Cornell University Law School as they seem to do the best job with updates and maintenance and at the end of the day the only thing you can seem to rely on is the actual…

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Understanding Your Odds with IRS Audit Technique Guides

Many taxpayers fear that aggressive deductions wave flags in front of IRS auditors and quite often I am asked what the chances are of being audited as if my opinion is some sort of a benchmark. The fact of the matter is that every tax return electronically filed is subject to some form of matching protocol,…

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