A Case for Cryptocurrency Tax Amnesty Good war planning evolves in stages, from strategic to tactical to political. The IRS appears to be in its operational phase, building a cryptocurrency campaign. Several developments signal a strong shift in IRS enforcement. These developments dwarf some 10,000 IRS letters sent… Read More
The Promise of Pennies on the Dollar
A Look Inside Tax Relief Companies A taxpayer recently described to me his experience at a tax relief company. You know the ones – late night TV ads, radio spots, settle your tax debt for pennies on the dollar, new tax laws where the IRS must settle with… Read More
IRS Releasing the Kraken?
The IRS does not create new Annual Reports on a whim. The newest report is one that all crypto users should view with caution. The Report is the work of the IRS’s Small Business/Self-Employed Tax (SB/SE) Division and it highlights a new Virtual Currency enforcement and compliance initiative…. 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
Gambling Away Taxpayer Rights
IRS Notices with Expired Due Dates
The IRS should avoid to a soon-to-be distressing event for taxpayers. Professor Keith Fogg of Harvard Law (and head of its Tax Clinic) recently wrote an article discussing a time-bomb blog post by Erin M. Collins, the National Taxpayer Advocate. Professor Fogg details in good order her comments… Read More
“Land Rich, Money Poor”
OIC Quick Sale Value in a COVID-19 World I am sorry Sir, the IRS rejected your Offer in Compromise (OIC) because you are “Land Rich, Money Poor”. The colloquialism describes a taxpayer with little or no disposable income but who owns real property with ample equity. This type… Read More