Situations by which Docketed U.S. Tax Court Cases Settle in IRS Appeals...
Schumann v. IRS: Reg. 1.469-2(f)(6) - The Nuanced Relationship Between Passive Losses & Self Rental Gains. Back to my friends that I previously wrote about who misunderstood passive activity and material participation. They are a married couple filing jointly and own a very successful business together structured...
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...
If you chose to represent yourself in an IRS Examination realize the IRS Revenue Agent (RA) or Tax Compliance Officer (TCO) assigned your file is trained very thoroughly to advocate on behalf of the US Government. One method used quite often is to create a (false)...
The Internal Revenue Code is a complex beast. In the lunacy of it all I've been asked to define 'trafficking' as it relates to 26 USC § 280E - Expenditures in connection with the illegal sale of drugs which states as follows: "No deduction or credit shall be allowed...
I've worked with many good people inside the IRS on a wide variety of cases. So please do not get me wrong I'm not bashing ALL IRS employees. However like any big bloated bureaucracy I've also worked with some real shit heads inside the IRS...
Ex parte communication is oral or written communication that takes place between any IRS Appeals employees such as Appeals Officers, Settlement Officers, Appeals Team Case Leaders, Appeals Tax Computation Specialists and employees of other IRS functions without the taxpayer's representative being given an opportunity to participate in the...
In my dealings with the US Treasury Department regarding worker classification disputes I have learned that although in reality there may be shades of gray distinguishing between what constitutes an employee and what constitutes an independent contractor the US Treasury has some very specific positions....
The IRS Office of Appeals resolves more than 100,000 tax cases each year. Employees staffed in this function are trained to resolve disputes taking into consideration the hazards of litigation as well as the benefits of efficient tax administration. They are not necessarily trained to advocate on...
Many taxpayers have both a dwelling unit and a principal place of residence. Understanding the difference between the two is important for a wide variety of reasons. The file that landed on my desk today involves such a matter. The taxpayer has a dwelling unit...