Tax Lawyer's Blog

Jack Townsend of Federal Tax Crimes blog posted about the recently released IRS FAQs on the voluntary disclosure program for taxpayers with offshore accounts.
Jack makes several important observations including:
Voluntary Disclosure requires a “noisy” disclosure. Simply sending in amended or delinquent returns or forms (”quiet disclosures”) does not qualify for the program.
 . . . those who have made [...]

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Reuters reported yesterday that President Obama wants to quadruple the IRS enforcement budget:
President Barack Obama proposed on Thursday nearly doubling funds to enforce U.S. tax laws next year, with an aim of more than quadrupling funding for tax compliance to $2.1 billion within five years.
The budget plan seeks $12.1 billion for the Internal Revenue Service, responsible [...]

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Many people, including some lawyers and tax professionals, erroneously believe that federal income taxes can never be discharged in a Bankruptcy proceeding.
Generally, tax debts that have been outstanding more than 3 years from the due date of the tax returns giving rise to them and that have been outstanding more than 240 days from the [...]

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In these bad economic times few of us have any extra cash laying around after we pay our monthly living expenses.
The IRS doesn’t care about that, right?
Wrong.
If you can’t pay your debt and can prove it, the IRS will stop (at least temporarily) attempting to collect the debt from you.
Non-Collectible Status
The IRS does not want [...]

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Tom Herman of the Wall Street Journal writes an interesting article titled How To Confess to Being a Tax Cheat and tells guilty-minded taxpayers what to do if they have a tax problem and are not an Obama Cabinet appointee.
First, he says, if you know you made a mistake on your tax return you may file an amended [...]

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In previous blog posts titled Tax Gap Widens Expect IRS to Get Tougher on Non-Compliers and IRS Continues to Step Up Enforcement Efforts, 2007 Statistics Reveal we wrote about the Obama administration’s plan to close the tax gap.
Here is what Mike Godfrey of Tax News.Com wrote about the IRS’s plan to close the international portion of the tax [...]

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For over 20 years we have represented hundreds of clients who have lived for a very long time in abject fear of the IRS.
Most of these clients, after we got them back in good standing with the IRS and on an installment plan to pay their back taxes, have told us that they felt like the weight of the [...]

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Once an assessment is made against you, your case gets sent to the IRS Collection Division.
There are two types of collection agents taxpayers encounter in the IRS collection process:

Automated Collection Distributors; and
Local Revenue Agents.

The Automated Collection System
The Automated Collection System was developed in the early 1980’s to allow the IRS to contact taxpayers by telephone [...]

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John Charles Vuckovich v. Commissioner of Internal Revenue – Here the taxpayer sued the IRS for inappropriately filing a federal tax lien against him.
The fact pattern is a familiar one:
The taxpayer failed to file tax returns and the IRS prepared returns for him based on available evidence.Â
After the expiration of the Notice of Deficiency, the IRS filed [...]

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Nina Olson, the National Taxpayer Advocate, has released her Annual Report to Congress (PDF).
In it she recommends something old and something new: Simplification of the tax code and enactment of measures that will minimize the burden on taxpayers who are struggling to pay their tax bills.
Ms. Olson said, “it is imperative for the IRS to consider the circumstances of taxpayers facing [...]

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