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Tax Articles

US v. Clarke SCOTUS Decision Favors Taxpayers

The SCOTUS clarified the 11th Circuit Court of Appeals in the United States v. Clarke Et. Al. that… “a taxpayer has a right to conduct an examination of IRS Officials regarding their reasons for issuing a summons when (s)he points to specific facts or circumstances plausibly raising an inference of bad faith.” JUSTICE KAGAN delivered the opinion of the Court as…


Defending Against Alter Ego Allegations

What is an “alter ego” allegation? Aside of course being one of several nuanced yet distinct stages of intoxication, when it comes to the IRS it seems from my perspective that there are several elements of the alter ego doctrine that arose out of the California Supreme Court in Minifie V. Rowley, 187 Cal 481,…


IRC 7216 Disclosure Issues to Consider When Selling Your Practice – Start With A Tight NDA

As many of you know who follow this blog I also currently serve in a voluntary capacity as the President of the Colorado Society of Enrolled Agents, a state affiliate chapter of the National Association of Enrolled Agents. In this capacity I have been blessed with the opportunity to connect with many different tax practitioners…


Tangible Assets Used In Converting Corn To Fuel Grade Ethanol Are Properly Included In Asset Class 49.5

A certain important person in my reality – my wife – is becoming increasingly interested in the business end of biomass refineries. You go girl. Funny but this interest also happens to correlate with a new file I am developing involving a farmer who owns an ethanol plant so hopefully we will be taking another…


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…


Form 5500 Pension Plan Penalty Filing Relief

For those of you like me presently wrestling with this issue the IRS recently came out with the following: Revenue Procedure 2014-32 establishes a one-year pilot program to provide relief to plan administrators who fail to timely file Form 5500 EZ. Revenue Procedure 2014-32 will be published in Internal Revenue Bulletin 2014-23 on June 2,…


Reporting Investments In Certain Foreign Corporations for U.S. Tax Purposes

As we increasingly become more connected on this planet US Taxpayers are compelled more than ever before to hold investments in multiple countries. As a direct result timely filing IRS Form 5471 is becoming profoundly significant. I’ve been involved with enough international tax matters to appreciate this form and subsequent schedules. This post is a summary of…


IRS Bills, Penalties and Interest Charges

Many people have been reaching out to me to learn specifically about what they are up against for failing to hit the tax deadline of April 15th. To help those of you in this situation I’ve highlighted below what I believe to be the top 10 most valid points in regards to IRS bills, penalties…