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Tax Articles

IRS Voluntary Disclosure Practice

IRS Voluntary Disclosure Practice TAX CRIMES – GENERALIRM Voluntary Disclosure Practice (1) It is currently the practice of the IRS that a voluntary disclosure will be considered along with all other factors in the investigation in determining whether criminal prosecution will be recommended. This voluntary disclosure practice creates no substantive or procedural rights for…


Tax Preparer Standard of Conduct – realistic possibility vs. more likely than not

The Small Business and Work Opportunity Tax Act of 2007 heightened the standards of conduct that must be met by tax preparers from ‘nonfrivolous’ to ‘reasonable’ basis for disclosed positions and from ‘realistic possibility of success on the merits (33%chance that a position would be sustained) to reasonable belief that the position would more likely…


IRS Statute of Limitations

Do Taxes Ever Expire? Many Americans believe that an IRS debt is a debt for life and that the tax collector can hound them to the grave. Thankfully, that is not the case and there are statutory time limits on the ability of the IRS to examine and collect taxes. Basically, IRS has 10 years…


Tax incentives for organ donations

Lisa Milot (Georgia) has published Find 45 Willamette L. Rev. 67′ target=_blank>The Case Against Tax Incentives for Organ Transfers, 45 Willamette L. Rev. 67 (2008). Here is the Conclusion: Upon initial consideration, providing tax incentives for organ donations might seem to reflect a sound legislative and ideological approach, consistent with the current tax code. In…


Taxable Incove Vs. Financial Accounting Income

Daniel N. Shaviro (NYU) has published The Optimal Relationship between Taxable Income and Financial Accounting Income: Analysis and a Proposal, 97 Geo. L.J. 423 (2009). Here is the abstract: The persistence of the book-tax gap, or excess of companies’ reported financial accounting income over their taxable income, suggests that accounting manipulation and tax sheltering remain…