To say that audits are slightly stressful for California business owners may be the understatement of the year. For many people in Sacramento County, audits can be one of those most intimidating parts about running a business. Even savvy business owners get nervous...
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Month: April 2012
‘Up with People’ filmmaker’s tax controversy ends favorably
In a court case closely watched by documentary filmmakers throughout California, Lee Storey, the producer and director of "Smile 'Til It Hurts: The Up with People Story," has prevailed in her tax dispute with the IRS. The tax controversy began a few years ago after...
Supreme Court rules against the IRS
In United States v. Home Concrete & Supply, LLC, the US Supreme Court affirmed the decision of the Fourth Circuit, holding that Section 6501(e)(1)(A) of the Internal Revenue Code, which extends the limitations period for the government to assess a deficiency...
IRS Advises that Sales at Prices Below Acquisition Cost Satisfy All-Events Test.
In field attorney advice memo 20121602F, the IRS determined that the "all-events test", which determines when a liability is incurred and deductible, is met when a wholesaler sells products to a pharmaceutical company at prices below the wholesaler's acquisition...
Hollow Victory for Taxpayer as IRS Acquiesces in Estate Tax Refund Suit but Declines to Actually Issue Refund.
In an Action On Decision (AOD), the IRS announced that it will acquiesce, in the result only of a decision in which the U.S. District Court held that a decedent's estate was entitled to a refund of deficiency assessed on contingent bequests. An AOD is a formal...
Why do California celebrities often owe back taxes?
If you owe back taxes to the IRS, then the IRS has the power to garnish your wages, impose liens on your property and even seize your assets. One method the IRS uses to accomplish this is through a federal tax lien. Filed with the local county courthouse, a federal...
Tax controversy: paying online sales taxes in California
As California residents prepare to file their taxes, there is one thing that tax officials are concentrating particularly hard on: sales taxes on items purchased online. Under state law, California residents must pay a "use tax" on any goods purchased online from a...
IRS Chief Counsel Issues Guidance on the Economic Substance Doctrine
IRS Notice CC-2012-008 announces new Chief Counsel Coordination Procedures for asserting the economic substance doctrine, which was recently codified in Internal Revenue Code Section 7701(o). The notice is intended to ensure that the economic substance doctrine is...
IRS Commissioner Will Leave in November, Recounts Offshore Initiatives
Internal Revenue Service (IRS) commissioner, Douglas Shulman, said he doesn't intend to stay in the job after his five-year term expires in November. "My plan is to leave at the end of my term," he said during a question-and-answer session today at the National Press...
Audits of wealthiest Americans increased in 2011
Perhaps unsurprisingly to many California residents, the IRS has recently stepped up its efforts with regard to audits of the wealthiest Americans. The largest increase was for those taxpayers who make more than $10 million per year, although significant increases...
