Knowledge is Power when negotiating with the IRS. You must know what they know to be successful. I want to help you obtain that knowledge. This is a short introductory video to tell you a little bit about myself and the TAX videos discussed on my Channel. If… Read More
Expanded Penalties Relative to Taxpayers with Interests in Foreign Trusts
A hard lesson for US taxpayer owners, settlors, or beneficiaries of foreign trusts was recently handed down in Emily S. Wilson et al. v. United States; No. 20-603. A U.S. citizen, by such relation to a foreign trust has the requirement to file IRS Form 3520 and IRS… Read More
Hardship Factor in Innocent Spouse Cases
In part, below is an excerpt from the publication of Procedurally Taxing, published August 24, 2021, and it is very instructive concerning the importance of the Hardship factor in making Innocent Spouse claims. Research of innocent spouse cases shows that proving financial hardship serves as the only way… Read More
“Specificity” Very Important in Claim for Refund Requests
Three recent Federal Court cases, Premier Tech v. United States, No. 2:20-cv-890-TS-CMR (D. Utah 2021); Intermountain Electronics v. United States, No. 2:20-cv-00501-JNP (D. Utah 2021); and Harper v. United States, 847 F. Appx. 408 (9th Cir. 2021), remind taxpayers of the “specificity” requirements in making Claims for Refund…. Read More
Important IRS Development in the Property Characterization of All Cryptocurrency
I have written previously on this Blog and for Cointelegraph on the Jarrett v. Commissioner case filed on May 26 with a Tennessee Federal District Court (Case No. 3:21-cv-00419), whereby the taxpayers sought a refund of taxes they had paid in connection with their generation of Tezos digital… Read More
The Nuts and Bolts of IRS Jeopardy Assessments for Tax Assessment Purposes
Jeopardy assessments for tax collection are rare, but they are a tool available to the IRS in extraordinary circumstances. Jeopardy assessments stand outside the normal IRS assessment procedures. In general, and in extraordinary circumstances, jeopardy assessments permit the IRS to assess additional income taxes first and only later… Read More