On June 5, 2012, the Internal Revenue Service (IRS) marked the third anniversary of its tax preparer initiative. The IRS also took the opportunity to renew its call for tax preparers to take and pass a new competency test as soon as possible.Prior to the IRS Return...
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IRS Mistakenly Sends Cleveland Waitress a Refund of $434,712
Virginian Hopkins, a waitress in downtown Cleveland, looks forward to receiving her IRS tax refund every year. This year, her expected refund of over $700 was supposed to go toward much needed car repairs. Much to her surprise, her refund check was nearly half a...
IRS Announces Fresh Start Initiative That Makes Changes to the Offer in Compromise Program
The Internal Revenue Service (IRS) recently announced, under release IR-2012-53, that they will expand their "Fresh Start" initiative by offering more flexible terms in their Offer in Compromise (OIC) program. An OIC is one method a taxpayer can use to settle his IRS...
Americans Living Abroad Get Caught By the U.S. Tax Code
It is no secret that the world is increasingly becoming a smaller place, especially when measured by the Internal Revenue Service's (IRS) long reach. An article in the New York Times discusses how Americans living abroad are coming under pressure to declare foreign...
Attorney Convicted of Tax Fraud and Obstruction of Justice Crimes
The U.S. Department of Justice (DOJ) and the Internal Revenue Service (IRS) recently announced that attorney Aristotle "Rick" Matsa was convicted of tax fraud and obstruction of justice related offenses, including witness tampering. Additionally, Mr. Matsa and his...
Taxpayer Not Required to Recognize Discharge of Indebtedness Gain on Installment Notes Until Disposition
required to recognize income from discharge of indebtedness, gain deferred pursuant to its installment sale, or gain on a disposition of an installment obligation.The taxpayer sold property to a new corporation controlled by a private equity firm in exchange for cash...
IRS Delays the Effective Dates for Reporting by Brokers for Debt Instruments, Options Transactions
In Notice 2012-34, the IRS has announced it will delay the proposed effective dates for information reporting by securities brokers for transactions related to debt instruments and options by one year.The new regulations recommend changes to the reporting requirements...
Tax Court gives Taxpayers a Big Victory
The Wall Street Journal just reported that "the Tax Court just blessed a technique that owners of closely held businesses-and wealthy families-can use to pass assets to heirs with a minimum of taxes and complications." The ruling in Wandry v. Commissioner is causing...
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...
