There is a new development in the area of compliance to the 5-year terms and conditions of accepted Offers in Compromise (OIC). For 5 years following an OIC acceptance, a taxpayer must remain fully paying and filing compliant or otherwise failure to do so constitutes a breach of… Read More
Change to the Internal Revenue Manual (IRM) and Collection Due Process (CDP) Deadlines
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
Not All Losses on Cryptocurrency Transactions Deductible
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
Encouraging News from the World of Tax Bankruptcies.
Tax practitioners may be encouraged by a recent bankruptcy ruling in the Southern District of New York on June 22, 2020 (In re Starling, 125 AFTR 2d 2020-2587, Bankr. S.D.N.Y. 2020). Practitioners generally support the idea that late-filed tax returns, even those filed after an IRS Substitute of… Read More
New Federal Court Case: Installment Agreements and Offer in Compromise Terms and Conditions
It is a good day when a Taxpayer receives an IRS Letter accepting his or her Offer in Compromise (“OIC”). However, the terms and conditions do not stop there. For 5 years following acceptance, there are several contractual obligations a Taxpayer must adhere to; so that the OIC… 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