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Administrative Procedures: Representation Before the IRS Appeals Office

A most important option available to a taxpayer is to appeal proposed audit adjustments to the IRS Appeals Office. Congress agrees and the IRS Restructuring and Reform Act of 1998, Pub. L. 105-206 (the "98 Act") required the Service reorganization plan to "ensure an independent appeals...

Adding Injury to Insult -- Getting the IRS to Pay Your Fees

Section 7430 (a) and (b) provide a taxpayer the right to recover costs, including fees of experts and attorneys paid or incurred: 1. In an administrative or court proceeding brought by or against the United States; 2. In which the taxpayer is the prevailing party; 3. Administration or litigation...

Tax Court Pretrial Procedures: Pretrial Orders and Conferences, Motions, and Settlement

I. STANDING PRETRIAL ORDER A. All Judges Now Use the Same Standing Pretrial Order. 1. The Court attaches the Standing Pretrial Order to the Notice Setting Case For Trial. 2. The Notice Setting Case For Trial is usually received about six months before the first day of the calendar on which...

Take the Money and Run: Extracting Equity on a Tax-Free Basis

A partnership is often chosen over other structures as the tax entity best suited for the conduct of a business. Inevitably, taxpayers and their advisors must consider the disposition or monetization of their interest in that business. Extracting a taxpayer's equity on a tax -efficient basis requires...

Scam: Income Tax Refund Under Section 501(c)(3)

Unfortunately, many citizens not familiar with Section 501(c)(3), are falling for a spam scam. The IRS is reporting that thieves are using a method called phishing, a technique used to acquire personal financial data in order to gain access to the financial accounts of unsuspecting consumers. Read...

Final Regulations Complete Guidance on Roth 401(k) Contributions

The Economic Growth and Tax Relief Reconciliation Act of 2001 introduced the Roth contribution program for 401(k) and 403(b) plans beginning in 2006, but with a limited duration set to expire at the end of 2010. The Pension Protection Act of 2006 eliminated this sunset provision, making the Roth contributions...

Treasury and IRS Release Report Addressing Strategy to Improve Voluntary Compliance with Tax Laws

On August 2, 2007, the Treasury Department and the IRS released a report titled “Reducing the Federal Tax Gap.” The report addresses the IRS’s strategy for reducing the tax gap. The report includes seven components and sets out compliance objectives, initiatives, and targeted completion...

Tax-Advantaged Transactions: Controversy and Planning Abound

The 2006 Federal Circuit Court of Appeals ruling in Coltec Industries, Inc. v. United States has given the Internal Revenue Service another weapon in its aggressive enforcement efforts against taxadvantaged transactions that are specifically structured to create corporate tax losses and deductions. The...

Circular 230 "Best Practices" and Written Advice Standards

Final Regulations under Circular 230, issued on December 20, 2004 (T.D. 9165) and as amended May 18, 2005 (T.D. 9201), establish standards for tax "practitioners" providing Covered Opinions and Other Written Advice as well as "best practices" applicable to all tax advice. The new...

Federal Income Tax Considerations in the Choice of Business Entity

I. Choices of Business Entity. A. Sole proprietorship. In conducting a business as a "sole proprietorship", an individual (the "sole proprietor") typically segregates a portion of his or her assets and dedicates them to a specific business purpose. A sole proprietorship involves...

Could you repeat that, please?

Just starting out in the Tax Law field? A basic knowledge of the terms of art is key to impressing your client or managing partner with your ability to handle Tax Law matters competently. Read on for a quick primer! Actions on Decisions - It is the policy of the IRS to announce whether it will follow...

Appealing an Audit

If your client can't stomach the tax bill received after an IRS audit, you may want to appeal to the IRS for a second look. So many taxpayers are able to downsize the amount of taxes, interest, and penalties owed by appealing that IRS agents grudgingly refer to the internal appeals process as the...

Irrevocable Life Insurance Trust

The irrevocable life insurance trust (ILIT) provides an accessible means of producing estate-tax-free dollars that is without equal in terms of the potential savings measured against what the grantor has to give up in return. Basics of Life Insurance and Estate Tax Estate taxation of life insurance...

Understanding Corporate Taxation

Introduction to the “Corporate Tax” and Resulting Double Taxation A “corporation” is a legal entity created under a state or other statute that allows “incorporation” by persons who become the “shareholders” of the corporation. In general, the corporation’s...

A Comprehensive Analysis of the "Stimulus Bill"

On February 17, 2009, President Obama signed major new legislation known as the “stimulus bill” which provides $787 billion of tax incentives and spending provisions to improve the economy. To understand the tax implications for your clients, read our recently released title, A Comprehensive...

American Recovery and Reinvestment Act of 2009

On February 17, 2009 President Obama signed into law the much publicized American Recovery and Reinvestment Act of 2009 (ARRA) which contained $787 billion worth of tax incentives and spending provisions intended to help revitalize the economy. The provisions range from significant relief for businesses...

Simplify Your Tax Research

Tax Research the Way You Want It Prefer to research tax issues by IRC section? By topic? Either way, LexisNexis® Tax Center makes it easy for you to access exclusive, authoritative analytical materials from CCH®*, Tax Analysts®, Shepard's ®, Matthew Bender® and Kleinrock-as...