Experience. Dedication. Results.
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...
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...
A 68-year-old economist who currently resides in California was recently charged with a number of tax crimes. In addition to tax evasion, he has additionally been charged with obstruction of the IRS, failure to file a tax return and failure to pay taxes. If convicted,...
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...
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...
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...
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...
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...
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...
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...
