The Tax Lawyer's Blog

IRS Offers Feeble Tax Relief in Hopes you Won’t Hire a Tax Professional

IRS collection officials do not want you to hire a tax professional. Why? Because when you represent yourself the IRS has a decided advantage. First, it is easier for them to intimidate and frighten you because they know you don’t know the law. Second, it makes it infinitely more likely that their procedural mistakes, their over-assessments and their violations of your…

Happy Birthday Pops

Today is my dad’s birthday. He would have been 88 years old. Happy birthday, pops.

TIGTA: Closely Held Businessmen More Likely to Structure Transactions to Avoid Taxes

The Treasury Inspector General for Tax Administration says the IRS needs to improve the quality of its audits of small corporations. Listen: TIGTA reviewed whether IRS examiners followed proper procedures and guidelines when auditing the returns of small corporations. The IRS defines small corporations as corporations with assets of less than $10 million. Many corporations in the…

TIGTA: 82% of Investment Theft Loss Claims are Erroneous

Taxpayers and their advisors have good reason to want to categorize losses as theft losses rather than investment losses. Theft losses are treated as ordinary losses and are deductible in the year incurred.¹ Investment losses are treated as capital losses and are limited to the amount of capital gains plus $3,000. It is, therefore, not surprising that TIGTA has…

More Swiss Banks to Disclose Names to IRS

Accounting Today reports that one of Switzerland’s oldest banks, Clariden Leu, has become the latest to cooperate with U.S. tax authorities in disclosing the names of American investors: The bank has begun notifying some of its U.S. customers that it plans to reveal their names and account information to the Internal Revenue Service, according to…

IRS Audit’s Google

I just googled “IRS audit of Google” and found this blog post by Paul Caron: Bloomberg, Google Tax Probe to Focus on Offshore Units, by Jesse Drucker: The IRS is auditing how Google avoided federal income taxes by shifting profit into offshore subsidiaries, according to a person with knowledge of the matter. The agency is…

AICPA Opposes IRS Fees, Fingerprinting of Tax Preparers

WebCPA reports that the American Institute of CPAs (AICPA) is asking the Internal Revenue Service to reconsider some of the fees it plans to charge for competency exams and fingerprinting as part of its tax preparer oversight program. The new fees would apply to individuals who are required to take the IRS competency examination in…

IRS To Fingerprint Tax Preparers

Yes, you read that correctly. The Journal of Accountancy reports that the IRS plans to start fingerprinting thousands of tax preparers as part of its oversight program and run the fingerprints through an FBI database: The IRS released more details on its tax preparer oversight program on Wednesday, and said registered tax return preparers would now be…

Another IRS Amnesty Program: The Voluntary Classification Settlement Program

The IRS is apparently so happy with the results of it’s offshore voluntary disclosure program that it has established a similar program in the area of worker classification. Michael Cohn of AccountingToday writes that the IRS has introduced a new voluntary compliance program Wednesday to convince employers to resolve their past issues with classifying employees as independent…

Tax Tweet of the Day

@GoodAttorneys Good Attorneys FED TAX-Did you know?  The IRS may not levy while an Offer In Compromise is pending decision, 30 days after a rejection, or during an appeal

Pappas on Taxation

I have decided to tweak this blog’s title a little bit by adding the subtitle “Pappas on Taxation.” Here’s a little anecdote that tells how I chose that name. When I started work at my first law firm, we’ll call it Hugo & Boss, I was assigned to work with the firm’s managing tax partner, Mr. Boss.…

No More New Tax Patents

 Who says they can’t get anything done in D.C.? The Journal of Accountancy reports that last Friday President Obama signed into law the Leahy-Smith America Invents Act (HR 1249), which reforms the U.S. patent system and stops the granting of patents for tax strategies: Under the act, any “strategy for reducing, avoiding, or deferring tax liability” is…

We Will Never Forget

Tax Alert: US Puts More Pressure on Swiss to Disclose Names of US Investors

Jack Townsend reports that the U.S. is redoubling it’s efforts to get Switzerland to disclose the names of its American offshore investors: In the continuing game of chicken between the Swiss government (perhaps better described for this purpose as the Swiss financial system) and the rest of the civilized world (at least the part that…

IRS Amnesty Deadline Extended to September 9, 2011 Due to Irene

The IRS has just announced that is extending the deadline for taxpayers to participate in the Offshore Voluntary Disclosure Initiative. The original deadline was August 31, 2011. This means there is still plenty of time for taxpayers with offshore bank accounts and unreported income to file for pre-clearance into the program and begin the process…