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9 Nov, 2008 4:58 am
... out counsel from an Atlanta tax attorney and/or Atlanta tax expert, is that the United States Southeastern Headquarters for the Internal
Revenue Service ("IRS") is located in Atlanta as are the Federal Tax Court and the Federal Court for
the Northern District of Georgia ... in Federal Court; you will likely be doing so in Atlanta, GA. Regardless of whether you believe the Internal Revenue Service ("IRS") is correct, the amount alleged in the
Notice of Deficiency is due and owing. As such, I strongly ...
25 Jan, 2008 10:38 am
... tax problems for the owners. Not paying payroll taxes is a big mistake since the Internal Revenue
Service (IRS) can collect the trust fund portion of the payroll tax debt from ... are different for a multi-member LLCs which is classified by
default as a partnership. According to IRS Revenue Ruling 2004-41, absent special circumstances such as transferee liability, members of ...
Revenue Code § 6672. If you or your company has a tax dispute contact Brager Tax Law Group, A P.C. Our tax lawyers represent ...
6 Jan 4:42 pm
... tax attorneys have identified at least two possibilities. The first is that investors may be entitled to a theft loss pursuant to Internal
Revenue Code Section 165. Unfortunately the year the loss can be deducted will probably be the subject of a ... likely that those who file
amended returns will be subjected to a tax audit, and that barring a change of heart by the Internal Revenue Service will need to hire a tax litigation attorney to assist them. Generally the tax law allows only three
years ...
30 Nov, 2007 5:08 am
... Exchange Services as the facilitator suffered losses due to the alleged misconduct of various defendants. In re Internal
Revenue Service § 1031 Tax Deferred Exch. Litig., ___ F.Supp.2d ___, 2007 WL 3119287, *1
(Jud.Pan.Mult.Lit. October 18, 2007). Plaintiff ... actions pursuant to 28 U.S.C. § 1407 in the District of Nevada. Defense attorneys for UBS Financial Services and counsel for
the California plaintiffs opposed pretrial coordination. Id. The Judicial Panel granted the motion to ...
22 Jan, 2008 6:00 pm
The Internal Revenue Service (IRS) has provided new
instructions for persons who wish to file wrongful levy claims against the IRS pursuant to Internal Revenue Code § 6343(b). These instructions are set forth in IRS Publication 4528 (Rev. Nov. 2007). If the IRS were to take your property to pay taxes that
someone else owed a wrongful levy claim is one of the ways to get your property back. Why would the IRS seize your property to pay someone ...
29 Feb, 2008 5:15 pm
... district court in Michigan dismissed a complaint challenging an Internal Revenue Service (IRS) tax levy on a couple's home. The couple owed income taxes of around $300, ... USC 2410, and they also filed an unauthorized collection action
under Internal Revenue Code § 7433 seeking damages. The court held that it lacked jurisdiction to
hear ... collection action because the couple hadn't exhausted their administrative remedies. Internal Revenue Code § 7433 allows a taxpayer to sue the IRS if it has engaged ...
5 Apr, 2007 4:39 pm
According to the United States Treasury Department Inspector General, the Internal Revenue
Service has had some problems protecting sensitive taxpayer information. Apparently between 2003 and 2006, almost 500 laptop computers
belonging to the Internal Revenue Service were lost or
stolen which may have exposed personal information of approximately 6000 taxpayers to identity thieves.
26 Jan, 2008 6:00 pm
The Internal Revenue Service (IRS) ( has reversed its
previous lenient policy of allowing the IRS Appeals Division to consider untimely protests of the Trust Fund Recovery Penalty (TFRP). ... a collection tool that the IRS uses to collect
payroll taxes owed by corporations. Under Internal Revenue Code § 6672 the IRS may collect the trust
fund portion of the taxes ... .7.6.1.6(5) (04-13-2006) The IRS has issued an internal memorandum which provides that if the tax appeal is not
filed in a timely manner ...
20 Jan, 2008 6:23 pm
The Internal Revenue Service (IRS) has issued FS 2008-10
warning taxpayers about tax fraud by tax preparers. The IRS points out that while most tax return preparers are honest a few are not, ... to disagree with the IRS. Many reputable tax
return preparers DO NOT ask to see receipts; nor are they required to. Recent guidance, by the IRS with respect to tax return preparer penalties pursuant to Internal Revenue Code Section 6694 confirms this. See IRS Notice 2008-13. While it may be helpful for a tax ...
15 Jan, 2008 12:05 pm
... . The Taxpayer Advocate's Report criticizes the IRS for not doing more to enforce tax preparer penalties. She notes that only $2.8 million in penalties were assessed for FYE Sept.
2007. However, this is about a 50% increase over the prior year. The Internal Revenue Service's top tax litigation attorney, IRS Chief Counsel Don Korb has already been quoted in IRS Notice, IR-2007-213 as saying that looking ...
18 Mar 6:59 am
According to Internal Revenue Service Commissioner Douglas
Shulman, investors who were defrauded by R Allen Stanford and Bernard Madoff can claim these theft losses as deductions when filing their taxes. The IRS announced these new procedures
on Tuesday. These new IRS rules are applicable to victims of any Ponzi scam but the tax filings must be filed for the year 2008. Theoretically, the investors would have been paying
capital gains taxes if their investments had made ...
12 Sep, 2007 3:44 am
... Smokeless Coal Co., 201 B.R. 163 (S.D.W.Va.1996). The West Virginia court, applying a definition of "successors in interest" found in Internal Revenue Service regulations, held that "purchasers of assets in
bankruptcy cannot be 'successors in interest' because ... they do not inherit the tax attributes of their predecessors." Id. at 171. That ruling was on appeal when the trustees filed
their complaint, and was later ...
6 Sep, 2008 5:20 am
Treasury Inspector General for Tax Administration: Unauthorized and Insecure Internal Web Servers Are Connected to the Internal Revenue Service Network,...
22 Jan, 2008 10:22 am
... Internal Revenue Service (IRS) is in a payroll tax
dispute with FedEx, and the IRS is proposing to assess tax and penalties against FedEx because it believes that the company has ... set forth in the ruling are: 1. Instructions 2.
Training 3. Integration 4. Services rendered personally 5. Hiring, supervising and paying assistants 6. Continuing ... loss 17. Working for more than one firm at a time 18.
Making services available to the general public 19. Right to discharge 20. Right to terminate Brager ...
8 Aug 7:07 am
IRS GETS HAMMERED BY THE D.C. CIRCUIT: In this case it took the Internal Revenue Service's ("IRS" or "the Service") aggressive interpretation of the tax code to part millions of Americans with
billions of dollars in excise tax collections. Even this remarkable feat did not end the IRS's creativity. When it finally conceded defeat on the legal front, the IRS got really
inventive and developed a refund scheme ...
11 Feb, 2008 4:16 am
The Internal Revenue Service (IRS) has published final
regulations on releases of federal tax liens and discharges of property. These regulations provide rules for how to go about obtaining the release of a federal tax lien after the tax
debt has been paid, or in situations where the statute of limitations on collecting the tax liability has expired. The regulations also provide rules for obtaining tax lien releases in
other situations. For example the IRS may issue a ...
30 Jan, 2008 1:41 pm
The Internal Revenue Service (IRS) says that tax audits
have increased during the fiscal year ended Sept. 30, 2007. For example the IRS audited 84% more returns of individuals with income of over $1 million dollars than the previous year.
This amounted to a tax audit rate of almost 10%.Tax audits of individuals with income of $200,000 or more rose almost 30%. Overall the IRS conducted tax audits of more individuals than
at any time since 1998. Business also came in for an increased ...
16 Jan, 2008 10:23 am
The Internal Revenue Service ("IRS") has released Notice
746 which provides information about penalties and interest, and lists the latest interest rates. According to the notice interest rates will go down one percentage point in January.
Not surprisingly the IRS generally pays 1% less on money it owes to taxpayers (overpayments) then it expects taxpayers to pay to it (underpayments). Interest is compounded daily, and is
in addition to penalties. The interest rates on underpayments ...
7 Mar, 2008 10:00 am
The Internal Revenue Service (IRS) has issued a memorandum
outlining its procedures for investigating tax preparers who show patterns of abuse, and thus may be subject to tax preparer penalties. The memo sets forth some interesting information.
At least in cases initiated through LMSB (Large and Midsize Business) Division the approval of the IRS Director of Field Operations is necessary. Once an investigation has been approved
the IRS may select up to 30 tax returns prepared ...
11 Mar 12:25 pm
The Internal Revenue Service decided this successful CEO's
salary was unreasonably high, but a three-judge Seventh Circuit panel disagrees: Circuit Judge Richard A. Posner issued this interesting ruling today on behalf of a unanimous panel. In
coverage of the ruling, The Milwaukee Journal Sentinel has a news update headlined "Menard wins big bucks tax case."
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