I thought I’d share some war stories from my legal representation of taxpayers. This is a story “in the trenches” of a tax audit and how an often-overlooked detail reversed a $750,000 IRS audit adjustment. Do not sleep on the details — they can make all the difference… Read More
Blog
Do I have to File Tax Returns to File Bankruptcy?
… the answer is, yes, if you have a tax filing obligation and you want the taxes to be eligible for discharge. But the bigger question is what happens in bankruptcy if you filed your tax returns late? If the IRS already filed your tax returns for you… Read More
YouTube Channel Introduction
This short introductory video explains our upcoming video series entitled, “Re-Think Your IRS Negotiations”. It provides an overview of the things we’ll discuss throughout the series — IRS tax debt, tax return preparation, tax defense, tax liens, tax levies, offers in compromise, IRS collections, IRS audits, IRS Appeals,… Read More
No Losses for Personal Crypto Transactions
All gains on cryptocurrencies are capital gains. However, not all losses are deductible. A taxpayer’s losses are not deductible on cryptocurrencies if the taxpayer’s activities are infrequent and do not rise to the level of investment activities. Instead, the taxpayer’s virtual currency transactions may be treated as “personal”… Read More
Taxpayer Friendly IRM Changes to CDPs
There is a new welcomed change to the Internal Revenue Manual (IRM) concerning Collection Due Process (CDP) Request deadlines. The old rule was that CDP Requests were determined to be timely when they were received by the correct IRS Office handling Appeals. The change to the IRM now… Read More
Less Concern over COVID 19 Tax Payments
A development in the taxpayer tax payments backlog. During the IRS closure due to COVID-19, the IRS accumulated backlog of millions of pieces of unopened mail in trailers set up outside IRS facilities. That resulted in significant delays in the processing of taxpayer’s tax payments. The IRS also… Read More