Recently, a Colorado business protested the IRS’ disallowance of their business expenses. The IRS alleges that the taxpayer was a Colorado medical marijuana dispensary to which Section 280E applies, as
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Civil Tax
IRS Provides Sample Letter Informing Taxpayers that Their Account was Referred to a Private Collection Agency
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Previously, we discussed Congress’s enactment of the FAST Act requiring the IRS to use private debt collection agencies to recover inactive tax receivables. In September, the IRS announced that it…
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IRS Audit Campaigns: What this means for taxpayers
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I was recently interviewed by the Wall Street Journal about the IRS LB&I audit campaigns discussed here. An interesting part of the conversation included a discussion of why the…
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Sixth Circuit Acknowledges Some Tax Laws Sanction Tax Avoidance
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In a strongly worded opinion that is very favorable for taxpayers who engage in sophisticated tax planning, the Sixth Circuit overturned a Tax Court opinion denying the benefits of a…
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California District Court Finds Failure to File FBARs was Willful Despite Application for Voluntary Disclosure Program
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The Bank Secrecy Act requires U.S. taxpayers to file FBARs with the U.S. Treasury disclosing any interest in, or signature authority over, foreign financial accounts with assets in excess of…
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IRS Announces 13 Issues Targeted Under its New Audit Campaigns
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On January 31, 2017, the IRS announced the initial rollout of its new audit strategy and identified 13 specific issues (campaigns) it will be targeting. The IRS is moving toward…
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Israel, the Republic of Korea and Saint Lucia Will Now Provide IRS Information on Bank Interest paid to Nonresident Aliens
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The IRS released an advanced version of Revenue Procedure 2016-56 that requires three more countries – Israel, the Republic of Korea and Saint Lucia – to participate in the automatic…
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Court Authorizes IRS to Seek Identities of Bitcoin Users and Users of Other Virtual Currencies
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On November 30th, a federal district court in California entered an order authorizing the IRS to serve a John Doe Summons on Coinbase Inc. seeking information about U.S.
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IRS Unveils Fast Track Mediation Collection Program, Offering Expedited Resolution for Certain Collection Cases
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Effective November 18, 2016, Revenue Procedure 2016-57 established the Small Business/Self-Employed (“SB/SE”) Fast Track Mediation Collection (“FTMC”) program to allow taxpayers and the IRS to resolve disputes quickly with an…
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IRS Announces Major Changes to Appeals Procedures
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In October 2016, the IRS declared that in-person conferences will no longer be the default method for Appeals conferences. The IRS also made several key Collection and Examination policy clarifications…
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