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9 Nov, 2008 4:58 am
... 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 ... and dire consequences. You should have an Atlanta tax lawyer, Internal
Revenue Service ("IRS") tax lawyer and/or Atlanta tax expert advise you on ... 30 Day Letter" request
you to send a letter to the IRS within 30 days stating your position and asking the IRS to reconsider the IRS agent's findings. ...
6 Jan 4:42 pm
... non-taxable. This position is supported by Greenberg v. Commissioner, a 1996 case decided by the United States Tax Court. The Internal Revenue Service ("IRS") believes, however, that the rule in Greenberg only applies in limited situations. IRS Legal ... 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 ...
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 ... to file a wrongful levy claim with the IRS. Another possible remedy is to file suit in United States District Court under Internal Revenue Code Section 7426(a)(1). Perhaps the most important thing to know about a wrongful levy claim is that it must be made within 9 months of the seizure,
so you ...
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.
12 Sep, 2007 3:44 am
... (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 ... that, after our own district court issued its judgment, and while the case was pending on appeal to this court, the United States Court of Appeals for the Sixth Circuit reached a decision in accord with that of the West Virginia
district court. See Holland ...
15 Feb, 2008 1:00 pm
... has reversed a decision of the United States Tax Court (Tax Court), and held that an
Internal Revnue Service Appeals Officer was not impartial within the meaning of Internal Revenue Code (IRC) § 6330. Cox v. Commissioner, No. 06-9004 (2008), reversing, Cox v. Commissioner, 126 T.
... was not impartial because of his prior involvment. The IRS refused, and ultimately the Coxes appealed to the United States Tax Court. The Tax Court reviewed IRS Treas. Reg. § 301.6330-1(d)(2 ...
3 Apr 5:10 am
The National Law Journal has compiled a list of the 20 Most Influential General Counsels in the United States. What have these exceptional general counsels done to receive this honor? According to the National Law Journal, they have proven to ... with The Walt
Disney Co., J.C. Penney Co. and the Robert Wood Johnson Foundation. Williams is an expert on Internal Revenue Service compliance for nonprofits. Her department represents all independent YMCAs on IRS matters.
Protecting the YMCA's marks and ...
26 Feb, 2007 5:50 am
... will consider the interplay between two distinct methods for recouping taxes collected by the Internal Revenue Service. The question presented in EC Term of Years Trust v. United States (No. 05-1541) is whether a party entitled to challenge ... from that of the taxpayer in Williams and
that it should therefore be able to rely on § 1346 to seek a refund. The United States responds that
Congress carefully tailored § 7426 as a remedy for parties in precisely the Trust's situation, which suggests that ...
29 Jan, 2008 12:41 pm
... is the only place for a tax controversy to be heard by independent judge, and not the Internal Revenue Service. It is where the bulk of federal tax litigation occurs. In the past when a Tax Court Petition was
... the U.S. Tax Court is located in Washington, D.C. it holds hearings around the United States
including Los Angeles, San Francisco, San Diego, and Fresno, ... at Brager Tax Law Group, A P.C. We handle cases not only in the United
States Tax Court, but also the federal district courts, and the ...
25 Mar 3:00 pm
It's a big deal for tax lawyers -- U.S. Court of Appeals for the First Circuit grants rehearing en banc in United States v. Textron Inc. On January 23, 2009, The New York Times contained an article headlined "I.R.S. Is Thwarted as Court Shields Textron Tax Papers" that
begins: The Internal Revenue Service suffered a setback
late Wednesday in its crusade against corporate tax shelters when an appeals court ruled that Textron, the maker ...
12 Oct 5:00 am
... the country."). Additional regulation, particularly with respect to compensation, could threaten this source of revenue by damaging
London's role as an international financial center. Perhaps unsurprisingly, the Economist reported in July that "[i]ndeed ... level executives and employees. Notions of director
"independence" and "expertise" already familiar to firms operating in the United States are prominent
features in the new code. Furthermore, the Code provisions require a marked change away from ...
15 Oct 6:02 am
... Galbenski, Unbound: How Entrepreneurship is Dramatically Transforming Legal Services Today (2009) at 34. At General Electric, more than half of the company's revenue came from outside the United States [HBR, Oct. 2009 at 58]. I
doubt ... .). For U.S. legal departments, the percentage of lawyers based outside the country will likely always lag the percentage of revenue
generated outside the US. What the formula eventually settles on for the typical department awaits benchmarks yet to be gathered and ...
14 Jun 11:30 am
... space on both sides, very near the border crossing, and the presence of a user-friendly international border crossing. Expeditors International, a large logistic
services company, has constructed a facility on the U.S. side of the fence, across ... ...." Read the rest of Garcia's posting here. We find this business confluence of China,
Mexico and the United States to be significant because it shows how the traditional political and
commercial borders have become increasingly interconnected in our ...
15 Jan, 2007 4:42 am
... as described in section 501(c)(3) of the Internal Revenue Code of 1986. The initial admission
period for religious workers entering the United States in R-1 status is limited to ... the R-1
status may be granted, but the total period for a person residing in the United States on R-1 status
may not exceed a total of five years. ... to engage in studies, travel freely in and out of the U.S., receive payment for services, and apply for permanent residency (green
card). Additionally, the spouse and any ...
1 Apr, 2007 6:22 pm
... , it is intended to do so--but it might alter that behavior in the direction of greater efficiency, by making potential injurers internalize accident costs. That is the
objective of tort law, though imperfectly achieved. Without tort liability, firms would have weak ... which the authors assume lead to greater than optimal liability, might instead
lead, in the countries they compare to the United States, to less than optimal liability. And even if
investment in the U.S. tort system has been carried ...
6 May 7:40 am
... and its beneficial owner or other affiliated foreign entities would be more likely to be subject to increased taxation in the United
States under the rules that apply to controlled foreign corporations, including subpart F. This provision would take ... of proving that an
individual does not own an offshore account on the individual, rather than requiring the Internal Revenue Service to prove that the individual does own the account. The tax lawyers at Hunton & Williams LLP have
extensive ...
21 Feb, 2007 11:07 am
... to strengthen the anti-money laundering laws, specifically with respect to transactions by foreigners and foreign institutions in the United States. [4] Hence, section 312 of the U.S.A. Patriot Act requires U.S. financial institutions ... , Feb. 14,
2007, available at [www.kansascity.com]. [8] Individual Taxpayer Identification Number (ITIN), Internal Revenue Service Website, at [www.irs.gov]. [9] Id. [10] Id. [11] Edwards, supra note 1. [12] Department of the
Treasury, supra note 4. [13] Id. [14] ...
17 Jun 9:13 pm
/**/ Image via Wikipedia From the US Attorney General (San Diego) press release about the the All States ATM Ponzi fraud. United States Attorney Karen P. Hewitt announced that today a federal grand jury sitting in San Diego ... Mail Fraud
and Conspiracy to Structure Financial Transactions. Hersch was arrested by federal agents from the Federal Bureau of Investigation and Internal
Revenue Service on April 16, 2009, at his residence pursuant to a criminal complaint charging him
with one count of mail ...
2 Nov, 2007 3:50 am
... on payments of dividends and other distributions made to third parties, and from filing tax returns with the Puerto Rican Internal
Revenue Service. Finally, the Commissioner's representatives discussed other reasons why they
consider Puerto Rico an ideal location ... and state-of-the-art insurance practices. • Puerto Rico has a privileged geographic location with open access to the mainland
United States and Latin America. • The island enjoys many benefits given its privileged status
vis-a-vis the ...
27 Feb, 2008 10:19 am
The Internal Revenue Service has opened an investigation
into Barack Obama's June 2007 speech (full text) to the United Church of Christ's General Synod. (See prior related ... ' political campaigns.
Today's Cleveland Plain Dealer reports that Obama, who is a long-time member of the United Church of Christ, was invited to address the General
Synod before he announced his candidacy for President of the United States. A number of people have
expressed puzzlement at the IRS's move. Rev. Barry W. Lynn, ...
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