Info@taxcontroversy.com

Blog

4 Tax Schemes From The IRS’s “Dirty Dozen” List That Can Get The Average Taxpayer In Serious Trouble

Avoiding tax schemes in Arizona

4 Tax Schemes From The IRS’s “Dirty Dozen” List That Can Get The Average Taxpayer In Serious Trouble On June 1 of this year, the Internal Revenue Service announced its “Dirty Dozen” list for 2022, which is a list of … Continue reading

How The Qualified Small Business Stock Exclusion Can Benefit Business Owners When Selling

How The Qualified Small Business Stock Exclusion Can Benefit Business Owners When Selling

  How The Qualified Small Business Stock Exclusion Can Benefit Business Owners When Selling     Tax Relief Opportunities & Requirements For Selling Under Section 1202   When it comes to selling a business, it is essential to consider how … Continue reading

New Jersey Committee Offers New Guidelines For CPAs & EAs On BOI Filings

New Jersey Committee Offers New Guidelines For CPAs & EAs On BOI Filings

New Jersey Committee Offers New Guidelines For CPAs & EAs On BOI Filings In January 2024, the Corporate Transparency Act went into effect impacting roughly 32.6 million businesses in the United States. The goal is to gain more transparency and … Continue reading

What Are The Potential Consequences Of The Supreme Court Transferring Regulatory Power From Agencies To Judges?

What Are The Potential Consequences Of The Supreme Court Transferring Regulatory Power From Agencies To Judges?

What Are The Potential Consequences Of The Supreme Court Transferring Regulatory Power From Agencies To Judges? In June, the Supreme Court considered and overturned the Chevron vs. Natural Resources Defense Council decision which was decided in 1984. This overturning is … Continue reading

Supreme Court Upholds Tax On Unrealized Gains: Key Implications For Investors

Supreme Court Upholds Tax On Unrealized Gains: Key Implications For Investors

Supreme Court Upholds Tax On Unrealized Gains: Key Implications For Investors On June 20th of this year, the Supreme Court made the decision to uphold the mandatory repatriation tax which allows taxes on unrealized gains, specifically in certain contexts. The … Continue reading

What Documentation Is Needed for Innocent Spouse Relief?

What Documentation Is Needed for Innocent Spouse Relief?

What Documentation Is Needed For Innocent Spouse Relief? When you are married and file jointly, you and your spouse are jointly responsible for your tax debt. But what if your spouse handles the finances and either underreported income or did … Continue reading

Dirty Dozen Tax Scams: Be Careful Of ‘Mills’ Pushing IRS Debt Solutions

Dirty Dozen Tax Scams Be Careful Of 'Mills' Pushing IRS Debt Solutions

Dirty Dozen Tax Scams: Be Careful Of ‘Mills’ Pushing IRS Debt Solutions Included in the yearly Dirty Dozen list of tax scams, the Internal Revenue Service (IRS) has once again issued a cautionary message to taxpayers regarding costly Offers in … Continue reading

IRS Recovers Funds From Fraudulent COVID Tax Credit Program

IRS Recovers Funds From Fraudulent COVID Tax Credit Program

IRS Recovers Funds From Fraudulent COVID Tax Credit Program Despite the IRS’s efforts to reclaim improperly distributed funds through the Employee Retention Credit (ERC), the program intended to help businesses keep employees during pandemic shutdowns was exploited by scammers due … Continue reading

Shocking Court Verdict Shakes Corporate America: Alabama Ruling on CTA Could Change Everything!

Shocking Court Verdict Shakes Corporate America: Alabama Ruling on CTA Could Change Everything!

Shocking Court Verdict Shakes Corporate America: Alabama Ruling on CTA Could Change Everything! In an unexpected and landmark decision, the U.S. District Court for the Northern District of Alabama recently found the Corporate Transparency Act (CTA) unconstitutional, stirring significant discourse … Continue reading

Alabama Court Ruling On The CTA: Implications On Nationwide BOI Reporting Companies

Alabama Court Ruling On The CTA Implications On Nationwide BOI Reporting Companies

Alabama Court Ruling On The CTA: Implications On Nationwide BOI Reporting Companies March 1, 2024, marked a pivotal moment in the legal landscape as a federal judge in Alabama’s Northern District Federal Court issued a significant ruling regarding the Corporate … Continue reading

Alabama Ruling Sends Shockwaves Through U.S. Business Regulations!

Alabama Ruling Sends Shockwaves Through U.S. Business Regulations!

Alabama Ruling Sends Shockwaves Through U.S. Business Regulations! A recent ruling from the Alabama Federal District Court has raised significant questions about the Corporate Transparency Act (CTA) and its implications for federal authority and business regulation. This decision challenges the … Continue reading

Billionaires’ Secret Exposed: IRS Targets Luxury Jets in New Audit Blitz!

Billionaires' Secret Exposed: IRS Targets Luxury Jets in New Audit Blitz!

Billionaires’ Secret Exposed: IRS Targets Luxury Jets in New Audit Blitz! The Inflation Reduction Act was passed in 2022 and as a part of it, the IRS was given funds to implement more resources towards seeking out high-income individuals who … Continue reading

IRS’s Game-Changing Plan To Extract $561 Billion From The Elite!

IRS's Game-Changing Plan To Extract $561 Billion From The Elite!

IRS’s Game-Changing Plan To Extract $561 Billion From The Elite! On February 6, 2024, the IRS released a new analysis stating that the amount of unpaid and overdue taxes they expect to collect from 2024 to 2034 is hundreds of … Continue reading

Do You Need to Include Your Company Applicant in Your BOI Report Submission?

Do You Need to Include Your Company Applicant in Your BOI Report Submission?

Do You Need to Include Your Company Applicant in Your BOI Report Submission? In 2021, the United States enacted the Corporate Transparency Act (CTA), mandating that US-registered companies disclose information on their beneficial owners. This legislation took effect on January … Continue reading

The Legal Implications of Submitting False Data in CTA Reports

The Legal Implications of Submitting False Data in CTA Reports

The Legal Implications of Submitting False Data in CTA Reports The Corporate Transparency Act, established in 2021 and implemented starting January 1, 2024, aims to curb illicit activities like money laundering, terrorist financing, and tax evasion, which were previously concealed … Continue reading

IRS’s Bold Crackdown: Millionaires & Mega-Corporations in the Crosshairs for Tax Evasion!

IRS's Bold Crackdown: Millionaires & Mega-Corporations in the Crosshairs for Tax Evasion!

IRS’s Bold Crackdown: Millionaires and Mega-Corporations in the Crosshairs for Tax Evasion! The IRS has been actively working to pursue 1,600 millionaires each owing $250,000 or more in overdue taxes as well as 75 business partnerships that claim $10 billion … Continue reading

A Guide For BOI Reporting: Who Qualifies As A Beneficial Owner Of A Business?

A Guide For BOI Reporting: Who Qualifies as a Beneficial Owner of a Business?

A Guide For BOI Reporting: Who Qualifies As A Beneficial Owner Of A Business? In 2021, Congress passed the Corporate Transparency Act requiring businesses to report their beneficial owners starting January 1, 2024. It is estimated that 32 million businesses … Continue reading

How to Ensure Your Business is Prepared for the Corporate Transparency Act?

How to Ensure Your Business is Prepared for the Corporate Transparency Act?

How to Ensure Your Business is Prepared for the Corporate Transparency Act? The Corporate Transparency Act (CTA) was enacted on January 1, 2021, to combat money laundering, financially supporting terrorism and other criminal activities. All registered US business entities that … Continue reading

The Corporate Transparency Act & Small Businesses: New Reporting Requirements Explained

The Corporate Transparency Act & Small Businesses: New Reporting Requirements Explained

The Corporate Transparency Act & Small Businesses: New Reporting Requirements Explained Beginning January 1, 2024, a significant update in reporting requirements will come into effect. This change mandates that roughly 32 million small businesses submit a Beneficial Ownership Information (BOI) … Continue reading

A Comprehensive Business Guide on the Corporate Transparency Act

A Comprehensive Business Guide on the Corporate Transparency Act

A Comprehensive Business Guide on the Corporate Transparency Act The Corporate Transparency Act (CTA) is set to come into effect on January 1, 2024. This significant law will have an impact on various entities, especially small businesses. These business owners … Continue reading

IRS Sounds the Alarm: The Growing Tax Gap & Its Implications!

IRS Sounds the Alarm: The Growing Tax Gap & Its Implications!

IRS Sounds the Alarm: The Growing Tax Gap and Its Implications! The Internal Revenue Service has released updated tax gap projections for tax years 2020 and 2021. Their current data reflects a significant increase from previous tax gaps. The agency … Continue reading

OnlyFans Stars & Other Social Media Influencers Beware of IRS Audits & Criminal Investigations

OnlyFans Stars & Other Social Media Influencers Beware of IRS Audits & Criminal Investigations

OnlyFans Stars & Other Social Media Influencers Beware of IRS Audits & Criminal Investigations OnlyFans has gained tremendous popularity over the past several years, especially during the COVID-19 pandemic when people were home with time on their hands. If you … Continue reading

Is Your Business Next? How the IRS’s AI Targets Partnership Discrepancies!

Is Your Business Next? How the IRS's AI Targets Partnership Discrepancies!

Is Your Business Next? How the IRS’s AI Targets Partnership Discrepancies! Earlier this month, the IRS announced that it will be utilizing some of its expanded funding from the Inflation Reduction Act to enhance tax compliance across key areas. Their … Continue reading

Billionaires’ Worst Nightmare: IRS Unleashes AI To Track Down Mega Tax Debts

Billionaires' Worst Nightmare IRS Unleashes AI To Track Down Mega Tax Debts

Billionaires’ Worst Nightmare: IRS Unleashes AI To Track Down Mega Tax Debts Last week, the IRS announced its newest effort aimed at aggressively pursuing 1600 millionaires who each owe $250,000 or more, along with 75 business partnerships with assets averaging … Continue reading

Big IRS Update: Essential E-Filing Changes Every Business Should Be Aware Of

Essential E-Filing Changes Every Business Should Be Aware Of

Big IRS Update: Essential E-Filing Changes Every Business Should Be Aware Of The Internal Revenue Service (IRS) has announced that effective January 1, 2024, most businesses will be required to electronically file Form 8300. This updated requirement is in compliance … Continue reading

Need a Skilled Former IRS Attorney To Handle Your Employee Retention Credit (ERC) IRS Audit?

Need a Skilled Former IRS Attorney To Handle Your Employee Retention Credit (ERC) IRS Audit

Need a Skilled Former IRS Attorney To Handle Your Employee Retention Credit (ERC) IRS Audit? Several ERC mills have popped up in the past year promising up to $26,000 in ERC to employers all over the country. A lot of … Continue reading

Tax Filing Gets a Digital Makeover: The Shocking IRS Update That Saves Hours!

Tax Filing Gets a Digital Makeover The Shocking IRS Update that Saves Hours!

Tax Filing Gets a Digital Makeover: The Shocking IRS Update That Saves Hours! The IRS announced late last week that they are offering a new way for taxpayers and tax professionals to submit electronic relief requests for specific international documents … Continue reading

Tax Agents No Longer Come To Your Door & Here’s Why

Tax Agents No Longer Come To Your Door & Here's Why

Tax Agents No Longer Come To Your Door & Here’s Why Effective immediately, IRS agents will no longer be stopping by taxpayers’ homes unannounced, citing safety concerns, stress, and anxiety for both their employees and taxpayers. This announcement is a … Continue reading

The Secret Tax Haven That The IRS Is Trying To Crack Down On

The Secret Tax Haven That The IRS Is Trying To Crack Down On

The Secret Tax Haven That The IRS Is Trying To Crack Down On Puerto Rico, an American territory in the Caribbean, has been offering tax incentives to a variety of people, especially high-income earners, hedge fund managers, and cryptocurrency traders, … Continue reading

IRS Cracks Down On Tax Evaders With New Technology

IRS Cracks Down On Tax Evaders With New Technology

IRS Cracks Down On Tax Evaders With New Technology The latest IRS news release announced improvements, updates, and ongoing changes to IRS procedures following the Inflation Reduction Act resources granted in 2022. The agency appears satisfied with its improved service … Continue reading

Huge Penalties For Unfiled Returns: This Is What Could Happen To You

Huge Penalties For Unfiled Returns This Is What Could Happen To You

Huge Penalties For Unfiled Returns: This Is What Could Happen To You In an appeal, the Ninth Circuit court recently reversed and remanded the Tax Court’s decision that taxpayers Ritchie Stevens and Julie Keene-Stevens did not owe deficiencies or penalties … Continue reading

Biden’s Dark Secret: IRS Email Corroborates Whistleblower’s Claim Of DOJ Meddling

Biden's Dark Secret IRS Email Corroborates Whistleblower's Claim Of DOJ Meddling

Biden’s Dark Secret: IRS Email Corroborates Whistleblower’s Claim Of DOJ Meddling IRS internal emails that were released last week provide compelling evidence of a whistleblower’s allegations that Department of Justice officials meddled in the Hunter Biden tax probe by blocking … Continue reading

The IRS Is Knocking: Get Ready For a Summer Of Tax Collection Notices!

The IRS Is Knocking: Get Ready For a Summer Of Tax Collection Notices!

The IRS Is Knocking: Get Ready For a Summer Of Tax Collection Notices! Automated collection notices that were temporarily stopped in response to the COVID-19 pandemic may begin coming back this summer, according to a report from the IRS. Although … Continue reading

Supreme Court Reverses Second Circuit Ruling On Right To Control Theory

Supreme Court Reverses Second Circuit Ruling On Right To Control Theory

Supreme Court Reverses Second Circuit Ruling On Right To Control Theory The U.S. Supreme Court ruled last month on Ciminelli v. United States, which was first heard in November 2022. The Supreme Court unanimously overturned the Second Circuit ruling in … Continue reading

Supreme Court Upholds IRS Authority To Issue Summons In Specific Collection Cases

Supreme Court Upholds IRS Authority To Issue Summons In Specific Collection Cases

Supreme Court Upholds IRS Authority To Issue Summons In Specific Collection Cases Last week, the U.S. Supreme Court unanimously ruled in favor of the IRS, upholding the agency’s authority to issue summons without prior notice in some situations. Although this … Continue reading

IRS Loses In Tax Court Failing To Find The Primary Issue On Family Ranch’s Tax Return

IRS Loses In Tax Court Failing To Find The Primary Issue On Family Ranch’s Tax Return

IRS Loses In Tax Court Failing To Find The Primary Issue On Family Ranch’s Tax Return Most taxpayers are overwhelmed at the thought of being taken to court by the IRS, which has a track record of winning a high … Continue reading

Understanding the Tax Division’s Policy on Voluntary Self-Disclosures for Companies

Understanding the Tax Division's Policy on Voluntary Self-Disclosures for Companies

Understanding the Tax Division’s Policy on Voluntary Self-Disclosures for Companies Last week, the Department of Justice updated their relatively new voluntary self-disclosure policy, which establishes standards for voluntary self-disclosure in corporate criminal enforcement actions. This policy indicates that when a … Continue reading

Proof of Work to Proof of Stake: Examining the Tax Implications of Cryptocurrency Consensus Changes

Proof of Work to Proof of Stake: Examining the Tax Implications of Cryptocurrency Consensus Changes

Proof of Work to Proof of Stake: Examining the Tax Implications of Cryptocurrency Consensus Changes The Internal Revenue Service has determined that units of cryptocurrency which transition from a proof of work consensus mechanism to a proof of stake consensus … Continue reading

Silver Law PLC Attorney Jason Silver Retained as Expert Witness in Attorney Malpractice Case for Criminal Tax Trial

Silver Law PLC Attorney Jason Silver Retained as Expert Witness in Attorney Malpractice Case for Criminal Tax Trial

Silver Law PLC Attorney Jason Silver Retained as Expert Witness in Attorney Malpractice Case for Criminal Tax Trial Silver Law, PLC lead attorney Jason Silver was recently retained to act as an expert witness in a malpractice case against an … Continue reading

Farhy v. Commissioner: Does The IRS Have Statutory Authority To Assess Section 6038(b) Penalties?

Farhy v. Commissioner: Does The IRS Have Statutory Authority To Assess Section 6038(b) Penalties?

Farhy v. Commissioner: Does The IRS Have Statutory Authority To Assess Section 6038(b) Penalties? This week, the U.S. Tax Court held in Farhy v. Commissioner that the IRS does not hold statutory authority under section 6038(b) to assess penalties against … Continue reading

IRS Warns Against Tax Scams & Schemes In Dirty Dozen Campaign

IRS Warns Against Tax Scams & Schemes In Dirty Dozen Campaign

IRS Warns Against Tax Scams & Schemes In Dirty Dozen Campaign Each year, the Internal Revenue Service issues a “Dirty Dozen” campaign, in which the agency provides details regarding common tax scams from that tax year. The last of this … Continue reading

IRS Warns of Fraudulent Employee Retention Credit (ERC) Claims Under Criminal Investigation

IRS Warns of Fraudulent Employee Retention Credit (ERC) Claims Under Criminal Investigation

IRS Warns of Fraudulent Employee Retention Credit (ERC) Claims Under Criminal Investigation Last week, the IRS issued a renewed warning that urges individuals to carefully review all of the Employee Retention Credit (ERC) guidelines before they claim the credit on … Continue reading

Bittner v. United States: US Supreme Court Revokes Penalty Ruling For Taxpayers With Foreign Financial Accounts

Bittner v. United States US Supreme Court Revokes Penalty Ruling For Taxpayers With Foreign Financial Accounts

Bittner v. United States: US Supreme Court Revokes Penalty Ruling For Taxpayers With Foreign Financial Accounts   Under the regulations of the Bank Secrecy Act (BSA), tax filers who hold specific financial interests in foreign accounts are required to file … Continue reading

What Is The New IRS Service Industry Tip Reporting Program?

What Is The New IRS Service Industry Tip Reporting Program

What Is The New IRS Service Industry Tip Reporting Program?   The Internal Revenue Service issued a notice this week detailing a proposed Service Industry Tip Compliance Agreement (SITCA) program that would enable the IRS to better receive voluntary tips … Continue reading

Should Taxpayers Continue To Report All Income From Digital Assets?

When Is A Qualified Appraisal Required For A Charitable Contribution Of Cryptocurrency

Should Taxpayers Continue To Report All Income From Digital Assets?   As the 2023 income tax return season is underway, an Internal Revenue Service (IRS) publication from this week reminded taxpayers of their obligation to report all income related to … Continue reading

When Is A Qualified Appraisal Required For A Charitable Contribution Of Cryptocurrency?

When Is A Qualified Appraisal Required For A Charitable Contribution Of Cryptocurrency?

When Is A Qualified Appraisal Required For A Charitable Contribution Of Cryptocurrency?   Taxpayers who want to make charitable contributions with cryptocurrency may be surprised to learn that a qualified appraisal is required when they claim a deduction on their … Continue reading

When Is FTA Applicable In Appeal Procedures On International Penalty Cases?

When Is FTA Applicable In Appeal Procedures On International Penalty Cases?

When Is FTA Applicable In Appeal Procedures On International Penalty Cases?   On December 7th of this year, the Internal Revenue Service (IRS) issued a memorandum from John E. Hinding, the Director of Specialized Examination Programs & Referrals. The memorandum … Continue reading

United States vs Banks: The Impact Of Loss Calculations On Sentencing Guidelines Under U.S.S.G. § 2B1.1

United States vs Banks: The Impact Of Loss Calculations On Sentencing Guidelines Under U.S.S.G. § 2B1.1

United States vs Banks: The Impact Of Loss Calculations On Sentencing Guidelines Under U.S.S.G. § 2B1.1 A recent case in the Third Circuit has shifted the guidelines of loss enhancement and sentencing for cases of tax fraud that fall under … Continue reading

IRS Prepares An Increase Of Hundreds Of Crypto Criminal Tax Cases

IRS Prepares An Increase Of Hundreds Of Crypto Criminal Tax Cases

IRS Prepares An Increase Of Hundreds Of Crypto Criminal Tax Cases Although the Internal Revenue Service (IRS) has made no secret of its emphasis on cryptocurrency cases, the criminal investigation unit of the IRS has just announced that they are … Continue reading

FTX Cryptocurrency Exchange Files For Chapter 11 Bankruptcy, Prompting Tax Confusion

FTX Cryptocurrency Exchange Files For Chapter 11 Bankruptcy, Prompting Tax Confusion

FTX Cryptocurrency Exchange Files For Chapter 11 Bankruptcy, Prompting Tax Confusion Cryptocurrency exchange company FTX filed for Chapter 11 bankruptcy on November 11, 2022, prompting a flurry of questions about the tax implications for its stakeholders. FTX consists of West … Continue reading

IRS-CI Releases Annual Report On Conviction Rate & Tax Fraud Enforcement Actions

IRS-CI Releases Annual Report On Conviction Rate & Tax Fraud Enforcement Actions

IRS-CI Releases Annual Report On Conviction Rate & Tax Fraud Enforcement Actions The criminal investigation branch of the IRS, IRS-CI, released a report last Thursday detailing their actions and successes from the fiscal year that began October 1, 2021, and … Continue reading

Cryptocurrency & Tax Compliance: What You Need To Know

Cryptocurrency & Tax Compliance: What You Need To Know

Cryptocurrency & Tax Compliance: What You Need To Know If you are one of the nearly 25% of Americans who own cryptocurrency, you might be wondering how to manage your tax returns in order to remain legally compliant. Because tax … Continue reading

IRS Confirms That Improperly Forgiven PPP Can Be Taxed

IRS Confirms That Improperly Forgiven PPP Can Be Taxed

IRS Confirms That Improperly Forgiven PPP Can Be Taxed In August, the IRS Chief Counsel’s Office issued an Advice Memorandum that provides guidance regarding Paycheck Protection Program loans (PPP), specifically in response to questions about PPP loan forgiveness and income … Continue reading

Does Biden’s Inflation Reduction Act Really Mean 87,000 More IRS Agents Are Coming?

Does Biden's Inflation Reduction Act Really Mean 87,000 More IRS Agents Are Coming?

Does Biden’s Inflation Reduction Act Really Mean 87,000 More IRS Agents Are Coming? Professionals and taxpayers have been talking extensively about the Inflation Reduction Act that was signed into law by President Joe Biden on August 16 of this year. … Continue reading

4 Tax Schemes From The IRS’s “Dirty Dozen” List That Can Get The Average Taxpayer In Serious Trouble

Avoiding tax schemes in Arizona

4 Tax Schemes From The IRS’s “Dirty Dozen” List That Can Get The Average Taxpayer In Serious Trouble On June 1 of this year, the Internal Revenue Service announced its “Dirty Dozen” list for 2022, which is a list of … Continue reading

When Does The Statute Of Limitations Begin If a Tax Return Was Not Previously Filed To an IRS Service Center?

Providing tax returns to the IRS in Arizona

When Does The Statute Of Limitations Begin If a Tax Return Was Not Previously Filed To an IRS Service Center? The Ninth Circuit Panel ruled in May that providing a tax return to an IRS agent initiates the statute of … Continue reading

Aspro v. Commissioner: IRS Denies Deductions For Management Fees of C Corporation

Calculating taxes in Arizona

Aspro v. Commissioner: IRS Denies Deductions For Management Fees of C Corporation The Eighth Circuit Court of Appeals sustained a tax court’s ruling that management fees for C corporation shareholders could be taxed as dividends. This case highlights the importance … Continue reading

Supreme Court Holds IRS To Their Own Standard In April Ruling

Supreme Court Holds IRS To Their Own Standard In April Ruling

Supreme Court Holds IRS To Their Own Standard In April Ruling The IRS suffered a significant defeat in the U.S. Supreme Court at the end of April after a unanimous decision authored by Justice Amy Coney Barrett in the case … Continue reading

President Biden Signs Executive Order Regarding Digital Assets

President Biden Signs Executive Order Regarding Digital Assets

President Biden Signs Executive Order Regarding Digital Assets On March 9, 2022, President Biden signed a broad and landmark executive order indicating his administration’s strategy regarding digital assets, which include increased regulation and oversight of cryptocurrency as well as prioritizing … Continue reading

IRS Announced Revisions & Updates To Voluntary Disclosure Practice Preclearance Request & Application Form

IRS Announced Revisions & Updates To Voluntary Disclosure Practice Preclearance Request & Application Form

IRS Announced Revisions & Updates To Voluntary Disclosure Practice Preclearance Request & Application Form Earlier this month, the Internal Revenue Service announced that they had revised and updated Form 14457, Voluntary Disclosure Practice Preclearance Request and Application, along with its … Continue reading

PPP (Payroll Protection Program) Issues: Possible Civil & Criminal Liability

PPP (Payroll Protection Program) Issues: Possible Civil & Criminal Liability

PPP (Payroll Protection Program) Issues: Possible Civil & Criminal Liability The fact that many businesses were impacted due to the pandemic and the government responses to it, such as mandatory lockdowns, etc., was not lost on Congress. In the weeks … Continue reading

Smaldino V. Commissioner: Gift Transfer Of LLC Member Interests Results In Large Tax Liability

Smaldino V. Commissioner: Gift Transfer Of LLC Member Interests Results In Large Tax Liability

Smaldino V. Commissioner: Gift Transfer Of LLC Member Interests Results In Large Tax Liability A US Tax Court decision earlier this month determined that an interspousal transfer of company interests to a trust was a gift tax liability despite being … Continue reading

IRS CI Increases Enforcement Actions Focused On PPP & EIDL Fraud, Money Laundering & Cybercrimes

IRS CI Increases Enforcement Actions Focused On PPP & EIDL Fraud, Money Laundering & Cybercrimes

IRS CI Increases Enforcement Actions Focused On PPP & EIDL Fraud, Money Laundering & Cybercrimes The criminal investigation branch of the IRS (IRS-CI) recently released detailed statistics from the 2020-2021 fiscal year, which began October 1, 2020 and ended September … Continue reading

Company Found In Contempt Of Court For Refusing Subpoena Regarding Dual-Purpose Communication

Company Found In Contempt Of Court For Refusing Subpoena Regarding Dual-Purpose Communication

Company Found In Contempt Of Court For Refusing Subpoena Regarding Dual-Purpose Communication Sometimes, attorneys find themselves wearing multiple hats, acting as both a lawyer and as a business advisor for their clients. These roles can become especially blurred in a … Continue reading

IRS Discusses More Extensive Oversight of S Corporations as More Officers Underreport Compensation

IRS Discusses More Extensive Oversight of S Corporations as More Officers Underreport Compensation

IRS Discusses More Extensive Oversight Of S Corporations As More Officers Underreport Compensation Arizona’s Top Tax Attorneys Explain The Treasury’s Audit & The Ramifications For Your Corporation A recent TIGTA audit analyzed whether officers of S corporations were intentionally underpaying … Continue reading

Ushio v. Commissioner: Taxpayers Erroneously Claim Section 1244 Stock Deduction

Ushio v. Commissioner Taxpayers Erroneously Claim Section 1244 Stock Deduction

Ushio v. Commissioner: Taxpayers Erroneously Claim Section 1244 Stock Deduction In the recent case of Ushio v. Commissioner, a couple attempted to claim a $50,000 ordinary loss using Section 1244 of the tax code. However, since the deduction claim did … Continue reading

Sells v. Commissioner: Tax Deduction Leaves Unanswered Questions In Conservation Easement Case

Sells v. Commissioner Tax Deduction Leaves Unanswered Questions In Conservation Easement Case

Sells v. Commissioner: Tax Deduction Leaves Unanswered Questions In Conservation Easement Case IRS Continues Tax Enforcement Efforts After Recent Conservation Easement Case The recent court case Sells v. Commissioner of the IRS demonstrates that the IRS will continue to aggressively … Continue reading

Taxpayer Fails To Meet Cohan Rule’s Tax Deduction Requirements

Taxpayer Fails To Meet Cohan Rule’s Tax Deduction Requirements

Taxpayer Fails To Meet Cohan Rule’s Tax Deduction Requirements Arizona’s Leading Tax Attorneys Discuss The Recent Case Of Fagenboym v. Commissioner When undergoing an audit, it’s common to utilize the Cohan Rule, which enables a taxpayer or business to claim … Continue reading

IRS Failure To Apply Anti-Injunction Act To CIC Services Will Lead To Tax Challenges

IRS Failure To Apply Anti Injunction Act To CIC Services Will Lead To Tax Challenges

IRS Failure To Apply Anti-Injunction Act To CIC Services Will Lead To Tax Challenges The Implications & Importance of CIC Services v. The Internal Revenue Service Recently, the Supreme Court overruled a lower court ruling affirming the use of the … Continue reading

IRS Announces The 2021 Dirty Dozen List Of Tax Schemes

IRS Announces The 2021 Dirty Dozen List Of Tax Schemes

IRS Announces The 2021 Dirty Dozen List Of Tax Schemes Every year, the IRS announces its list of common tax schemes that it has encountered and is focusing its efforts on enforcing. This year, the tax agency created four categories … Continue reading

Growing Cryptocurrency Popularity Presents Serious Tax Evasion Threat

Growing Cryptocurrency Popularity Presents Serious Tax Evasion Threat

Growing Cryptocurrency Popularity Presents Serious Tax Evasion Threat Cryptocurrency & Tax Evasion: The Biden Administration Is Proposing Stronger Reporting Requirements Cryptocurrency is quickly becoming a hot topic in the news. Business leaders and politicians are commenting on its rise and … Continue reading

Battat v. Commissioner: Tax Penalties Called Into Question

Battat v. Commissioner Tax Penalties Called Into Question

Battat v. Commissioner: Tax Penalties Called Into Question Penalty Lacked Proper Approval: The Case Of Battat v. Commissioner Of The IRS So much of tax law is in the details – and a couple recently discovered that, to their benefit. … Continue reading

Crypto Transfers Exceeding $10,000 Required To Be Reported To IRS

Crypto Transfers Exceeding $10,000 Required To Be Reported To IRS

Crypto Transfers Exceeding $10,000 Required To Be Reported To IRS IRS Increases Enforcement Of Cryptocurrency Reporting The Biden Administration has introduced several proposals recently to improve enforcement of tax laws by the IRS, not only to raise revenues, but also … Continue reading

President Biden Proposes a Substantial Increase In IRS Funding

President Biden Proposes a Substantial Increase In IRS Funding

President Biden Proposes a Substantial Increase In IRS Funding The IRS Will Increase Oversight Of High-Income & Corporate Tax Returns The IRS may soon be coming for a lot of delinquent taxpayers – particularly those who have a lot of … Continue reading

Tax Laws Prepared For Enforcement By Justice Department Tax Division

Tax Laws Prepared For Enforcement By Justice Department Tax Division

Tax Laws Prepared For Enforcement By Justice Department Tax Division The IRS Has Extended The Tax Filing & Payment Deadline Due To The COVID-19 Pandemic The pandemic has made everything look a little different this year, including how we file … Continue reading

IRS Demonstrates Hard Fork Ruling Applications to 2017 Bitcoin Hard Fork

IRS Demonstrates Hard Fork Ruling Applications to 2017 Bitcoin Hard Fork

IRS Demonstrates Hard Fork Ruling Applications to 2017 Bitcoin Hard Fork IRS Issues Guidance On The Tax Treatment of Bitcoin “Hard Fork” In 2017, a “hard fork” was created that put Bitcoin transactions on a separate path from Bitcoin cash … Continue reading

IRS Advises Predatory Micro-Captive Insurance Participants To Leave Arrangements

The IRS is continuing its crackdown on micro-captive insurance arrangements. If you're involved, contact one of our experienced Las Vegas tax attorneys.

IRS Advises Predatory Micro-Captive Insurance Participants To Leave Arrangements The IRS Continues Its Efforts To Root Out Tax Evasion & Fraud The IRS is continuing its crackdown on micro-captive insurance arrangements, and last week, it issued a new plea to … Continue reading

Court Allows IRS To Serve Summons To John Doe For Cryptocurrency Usage

IRS Serves Summons To John Doe For Cryptocurrency Usage

Court Allows IRS To Serve Summons To John Doe For Cryptocurrency Usage Taxpayers Have To Pay The Appropriate Taxes On Any Virtual Currency Gains They Make The IRS has been focusing on efforts to ensure that taxpayers are properly reporting … Continue reading

Tax Court Throws Out Fraud Penalty Because IRS Agent Did Not Obtain Proper Management Approval

Tax Court Throws Out Fraud Penalty Because IRS Agent Did Not Obtain Proper Management Approval

Tax Court Throws Out Fraud Penalty Because IRS Agent Did Not Obtain Proper Management Approval Former IRS Tax Attorneys Discuss Recent Cases Of Tax Court Tackling Supervisory Approval of Penalties Congress approved Internal Revenue Code section 6751 as part of … Continue reading

IRS Wants Businesses To E-File When Reporting Large Cash Transactions

IRS Wants Businesses To E-File When Reporting Large Cash Transactions

IRS Wants Businesses To E-File When Reporting Large Cash Transactions IRS Reporting Requirements: Business Cash Transactions Over $10,000 Must Be Filed Under Form 8300 Most businesses traffic is smaller transactions. Think about your local convenience store taking in sales of … Continue reading

Business Deduction Restrictions For Licensed Marijuana Dispensaries Upheld By Tax Court

Business Deduction Restrictions For Licensed Marijuana Dispensaries Upheld By Tax Court

Business Deduction Restrictions For Licensed Marijuana Dispensaries Upheld By Tax Court Experienced IRS Tax Attorneys Discuss Tax Deduction Restrictions On Marijuana Businesses Businesses may be able to sell marijuana in states where it has been made legal, but selling marijuana … Continue reading

Tax Court Continues To Disallow Tax Deductions For Marijuana Businesses

Tax Court Continues To Disallow Tax Deductions For Marijuana Businesses

Tax Court Continues To Disallow Tax Deductions For Marijuana Businesses Expert IRS Tax Attorneys Discuss Tax Court Decisions on Medical Cannabis Dispensaries On February 17, 2021, The United States Tax Court issued an opinion affirming all of its prior decisions … Continue reading

Court Finds Penalized FBAR Tax Filings Not Excessive

Court Finds Penalized FBAR Tax Filings Not Excessive

Court Finds Penalized FBAR Tax Filings Not Excessive Expert Scottsdale Tax Lawyers Discuss The Case Of a Penalized Taxpayer For Failure to Report All Foreign Accounts On An FBAR Filing The IRS has many measures in place to crack down … Continue reading

Arizona Department of Revenue Issues New Adult Use Marijuana Website

Arizona Department Of Revenue Issues New Adult Use Marijuana Website

Arizona Department of Revenue Issues New Adult Use Marijuana Website Tax Lawyers Discuss AZDOR’s New Tax Assistance Website For Marijuana Businesses Marijuana continues to be a federally illegal substance even though most states across the country allow legal sales, either … Continue reading

Underreported Incomes and Unfiled Returns Yield Billions in Unpaid Taxes

Underreported Incomes and Unfiled Returns Yield Billions in Unpaid Taxes

Underreported Incomes and Unfiled Returns Yield Billions in Unpaid Taxes Gilbert’s Tax Attorneys Go in Detail About the Form 1099-K in IRS Findings Two days before the new year started, The Treasury Inspector General for Tax Administration (TIGTA) issued a … Continue reading

Learn All About FinCEN’s New Regulation On Crypto & Virtual Currency

Learn All About FinCEN’s New Regulation On Crypto & Virtual Currency

Learn Everything About FinCEN’s New Regulation On Crypto & Virtual Currency Scottsdale’s Preeminent Tax Attorneys Examine FinCEN’s Laws On FBAR Virtual Money Virtual currency has long since exceeded the point that everyone thought it was a novelty for risky entrepreneurs. … Continue reading

Sabolic Petitioner vs. CIR: Tip Earnings under Scrutiny

Sabolic Petitioner vs CIR Tip Earnings Under Scrutiny

Sabolic Petitioner vs. CIR: Tip Earnings under Scrutiny As our Nevada tax lawyers have experienced for many years, people who work for tips find themselves in a unique position when it comes to reporting their taxes. They are employees, yet … Continue reading

Coffey vs. CIR: Tax Filing With the Virgin Islands

Coffey vs. CIR: Tax Filing With the Virgin Islands

Coffey vs. CIR: Tax Filing With the Virgin Islands A Statute Of Limitations Begins When The Taxpayer Files The Return In an appeals case in Coffey vs. Commissioner, the IRS sought to overturn a lower court ruling that found in … Continue reading

IRS to Target Tax Preparers Who’ve Failed to File their Own Returns

IRS to Target Tax Preparers Who’ve Failed to File their Own Returns

IRS to Target Tax Preparers Who’ve Failed to File their Own Returns Our Tax Attorneys Explain The New Strategy IRS has for Tax Professionals The IRS has announced a number of efforts recently to increase enforcement of tax compliance, and … Continue reading

Corporations Penalized for Failing to Pay Taxes on Time

Corporations Penalized for Failing to Pay Taxes on Time

Corporations Penalized for Failing to Pay Taxes on Time Companies Must Prove Lack Of Tax Payments Is Not Due To Negligence A Court of Federal Claims recently ruled that a corporation charged with failing to pay payroll taxes in a … Continue reading

IRS Expansion Raises Concerns of Politicized Tax Agency

IRS Expansion Raises Concerns of Politicized Tax Agency

IRS Expansion Raises Concerns of Politicized Tax Agency Tax Attorneys Discuss Possible Link Between The IRS And Political Agendas Some Democratic leaders are now pushing for a $5.2 billion increase to the IRS for expanding its enforcement activities – an … Continue reading

How is the IRS Prioritizing High-Income Non-Filers?

How is the IRS Prioritizing High-Income Non-Filers?

How is the IRS Prioritizing High-Income Non-Filers? The COVID-19 pandemic has left many struggling to make ends meet or to keep their businesses open. Meanwhile, there have been many conversations at the national level about how economic inequality and how … Continue reading

Criminal Investigation from IRS Reveals $2.3 Billion in Tax Fraud

Criminal Investigation from IRS Reveals $2.3 Billion in Tax Fraud

Criminal Investigation from IRS Reveals $2.3 Billion in Tax Fraud The Internal Revenue Service this week released the annual report of its Criminal Investigation Division, which included the identification of more than $10 billion in tax fraud and other financial … Continue reading

Oropeza v. Commissioner: Tax Court Decision, 155 T.C. No. 9 (2020)

Oropeza v. Commissioner: Tax Court Decision, 155 T.C. No. 9 (2020)

Oropeza v. Commissioner: Tax Court Decision, 155 T.C. No. 9 (2020) A tax court issued an opinion in October in favor of a micro-captive insurance owner who had been ordered to pay penalties on income reported in the 2011 tax … Continue reading

IRS Offers Assurances of Deductibles for Partnerships & S Corporations

IRS Offers Assurances of Deductibles for Partnerships & S Corporations

IRS Offers Assurances of Deductibles for Partnerships & S Corporations In advance of proposed regulations surrounding income tax deductions for certain businesses, the Internal Revenue Service (IRS) issued rules that would be included if those regulations are passed. The proposed … Continue reading

IRS Hikes Insurance Scam Rules for Oct. 15 Filing Deadline

IRS Hikes Insurance Scam Rules for Oct. 15 Filing Deadline

Oct. 15 Filing Deadline: IRS Increases Abusive Micro-Captive Insurance Schemes Regulations The IRS has set a deadline of Oct. 15 for those who may have participated in an abusive micro-captive insurance transaction to negotiate a settlement. That deadline is fast … Continue reading

IRS Launches Marijuana Industry Webpage on IRS.gov

IRS Launches Marijuana Industry Webpage On IRS.gov

IRS Launches Marijuana Industry Webpage on IRS.gov Marijuana continues to be a federally illegal substance even though most states across the country allow legal sales, either recreationally, medicinally, or both. Because the sale of marijuana is federally illegal, marijuana business … Continue reading

IRS Warns of Higher Penalties for Tax Returns Filed after Sept. 14

IRS Warns of Higher Penalties for Tax Returns Filed after Sept. 14

IRS Warns of Higher Penalties for Tax Returns Filed after Sept. 14 This year, tax season may have seemed a bit more lax for a lot of taxpayers. The filing deadline was extended to July 15 as a result of … Continue reading

Fighting Illicit Activities through Cash Transaction Reporting

Fighting Illicit Activities through Cash Transaction Reporting

Fighting Illicit Activities through Cash Transaction Reporting A lot of criminals deal in cash in order to avoid detection by the authorities, including tax officials. But they know that if law enforcement starts looking closer into their lifestyles, they need … Continue reading

12 Threatening Tax Scams the IRS Urges Consumers to Watch Out For

12 Threatening Tax Scams the IRS Urges Consumers to Watch Out For

12 Threatening Tax Scams the IRS Urges Consumers to Watch Out For Tax scams are common. Everyone has to pay taxes, and people looking to steal your money or information will use that process to their advantage to take what … Continue reading

Is an Amended Tax Return Right for Your Client?

Is an Amended Tax Return Right for Your Client

Is an Amended Tax Return Right for Your Client? It’s easy enough for taxpayers to file an amended return using the form 1040-X. Usually, people opt to amend a return because they realize they can lower what they owed on … Continue reading

File Your Taxes Now, Before It’s Too Late

File Your Taxes Now, Before It’s Too Late

File Your Taxes Now, Before It’s Too Late The coronavirus has upended the lives of many. Some have gotten seriously ill, and some have even died. Many are struggling to juggle the demands of working remotely while also ensuring their … Continue reading

District Court Rules FBAR Penalty Doesn’t Apply to Number of Accounts

District Court Rules FBAR Penalty Doesn’t Apply to Number of Accounts

District Court Rules FBAR Penalty Doesn’t Apply to Number of Accounts Tax cases can make it to higher courts on appeal, and when they do, the decisions that the courts reach can clarify tax law or even change it. In … Continue reading

Excessive Fines Clause in Eighth Amendment Not Breached with FBAR Penalty

Excessive Fines Clause in Eighth Amendment Not Breached with FBAR Penalty

Excessive Fines Clause in Eighth Amendment Not Breached with $12.9 Million FBAR Penalty If you invest your money in other countries, or if you save money in foreign bank accounts, you have to report those assets to the IRS and … Continue reading

Paycheck Protection Program Loans: Expenses Paid are Not Deductible

Paycheck Protection Program Loans: Expenses Paid are Not Deductible

Paycheck Protection Program Loans: Expenses Paid are Not Deductible Many businesses have had to close or move their operations online because of the COVID-19 quarantine across the country. Some businesses have taken a hit to their profits, but they’ve been … Continue reading

IRS Announces Focus on Non-Filing Taxpayers, to Step Up Enforcement Efforts

IRS Announces Focus on Non-Filing Taxpayers, to Step Up Enforcement Efforts

IRS Announces Focus on Non-Filing Taxpayers, to Step Up Enforcement Efforts The IRS is using more tools at its disposal to focus on those taxpayers who are not filing their annual tax return. Specifically, the agency will be focusing on … Continue reading

IRS Announces It Will Pay More Visits to High-Income Taxpayers

IRS Announces It Will Pay More Visits to High-Income Taxpayers

IRS Announces It Will Pay More Visits to High-Income Taxpayers It’s common knowledge that high-income earners and business owners often find ways to minimize or avoid their tax liability. They can do it legally by hiring accountants and other tax … Continue reading

IRS Implements Tax Compliance Education

Woman Showing Papers To Tax Consultant

IRS Implements Tax Compliance Education The IRS utilizes a number of strategies to ensure that individuals and businesses pay the taxes they owe and to do so on time. The agency provides plenty of information and education to ensure that … Continue reading

Trump’s SECURE Act: How It’s Changing Retirement

President Donald Trump

Trump’s SECURE Act: How It’s Changing Retirement Just ahead of the holidays, President Trump signed the SECURE Act into law as part of an overall spending bill. The Act, which is an acronym for Setting Every Community Up for Retirement … Continue reading

2019 Tax Penalties and How to Avoid Them

Calculator and Tax Document

2019 Tax Penalties and How to Avoid Them When you think of tax penalties, you may think only of the penalties you would pay for not paying your taxes on time or for committing some criminal offense. But there are … Continue reading

IRS Releases 2019 Report of Criminal Enforcement, Celebrates 100 Years of Investigations

IRS Releases 2019 Report of Criminal Enforcement, Celebrates 100 Years of Investigations Every year, the Internal Revenue Service publishes a report with information about its criminal enforcement efforts over the preceding 12 months. This past week, the IRS released the … Continue reading

Tax Court Denies Marijuana Dispensary’s Deductions and Rules that Section 280E is Not a Penalty Provision; Dissenting Opinion Finds that Section 280E is a Penalty

Tax Court Denies Marijuana Dispensary’s Deductions and Rules that Section 280E is Not a Penalty Provision; Dissenting Opinion Finds that Section 280E is a Penalty On October 23, 2019, the United States Tax Court issued its latest opinion regarding the … Continue reading

IRS Guidance on Tax Treatment for Virtual Currency

IRS Guidance on Tax Treatment for Virtual Currency

IRS Guidance on Tax Treatment for Virtual Currency Virtual currency is still currency in the eyes of the law. Why shouldn’t it be? You spend real money to buy it, and you can use it just like real money to … Continue reading

New Tax Gap Estimates from IRS Compliance Rates Remain Unchanged

blog: New Tax Gap Estimates from IRS Compliance Rates Remain Unchanged

New Tax Gap Estimates from IRS: Compliance Rates Remain Unchanged Every few years, the Internal Revenue Service looks at the latest tax gap: The difference between the taxes that are owed and the taxes that have been paid. The higher … Continue reading

IRS Settlement: Micro-Captive Insurance Schemes

IRS Settlement: Micro-Captive Insurance Schemes

IRS Settlement: Micro-Captive Insurance Schemes Companies often form what are known as “captive insurance companies” to protect themselves against loss. They create these companies themselves, invest their own money into them, and then use that money as insurance in case … Continue reading

IRS Proclaims New Tax Filing Obligations for Specific Expatriated Individuals

blog: IRS Proclaims New Tax Filing Obligations for Specific Expatriated Individuals

IRS Proclaims New Tax Filing Obligations for Specific Expatriated Individuals Just because you give up your U.S. citizenship doesn’t mean that you get out owing Uncle Sam. In an effort to get some former citizens to make good on their … Continue reading

IRS Lead Development Center and Devious Tax Schemes

Man In A Writing In a Paper On A Desk

IRS Lead Development Center and Devious Tax Schemes Taxes are big money. That’s why you have so many people out there trying to scam taxpayers out of their money, and that’s why you have so many taxpayers trying to avoid … Continue reading

2017 Las Vegas Tip Income Audits

Las Vegas Tip Income

2017 Las Vegas Tip Income Audits The IRS recently began tip income audits of Las Vegas nightclub and entertainment venue employees for the tax year 2017. This comes on the heels of 2016 audits of these same individuals. 2017 audits … Continue reading

Provisions of Taxpayer First Act Go into Effect

President Donald Trump

Provisions of Taxpayer First Act Go into Effect Earlier this summer, President Trump signed into law the Taxpayer First Act with the goal of overhauling the IRS and improving the customer service provided to taxpayers. Specifically, the act puts limits … Continue reading

Taxpayer Advocate Service Issues Report on Tax Credit, Creates Map of Taxpayers

Calculating Debts

Taxpayer Advocate Service Issues Report on Tax Credit, Creates Map of Taxpayers The Taxpayer Advocate Service (TAS) issued a report earlier this month that makes recommendations for the earned income tax credit in order to increase participation among eligible taxpayers. … Continue reading

IRS Sending Letters to Cryptocurrency Owners about Unpaid Taxes

Bitcoins

IRS Sending Letters to Cryptocurrency Owners about Unpaid Taxes If you buy and sell stocks, you likely know that you have to pay taxes on any gains that you make. Just because the money came from speculation and not your … Continue reading

Got an IRS Notice? Don’t Panic

Woman Calculates Tax

Got an IRS Notice? Don’t Panic Opening your mailbox and finding anything marked from the IRS can fill you with dread – unless it’s about time for you to get a refund. But even when you’re expecting a refund, you … Continue reading

IRS Bars State SALT Cap Workarounds

Currency of the United States

IRS Bars State SALT Cap Workarounds The IRS rewards people who give money to charities, to a certain extent. It allows people who contribute to charities to deduct that money on their taxes as an itemized deduction, thereby reducing their … Continue reading

Las Vegas Tip Agreements And The Risk Of Opting Out

Client Tipping

LAS VEGAS TIP AGREEMENTS AND THE RISK OF OPTING OUT Many Las Vegas residents are nightclub, casino, or restaurant employees, and earn tip income in addition to their regular wages. Tips are considered wages and are subject to employment taxes, … Continue reading

Taxing Money from Trips and the Penalty Issue

Businessmen At The Airport

Taxing Money from Trips and the Penalty Issue When people travel for business within the United States and outside of the United States, there are tax laws to consider. Employers and employees often do not know, understand, or apply the … Continue reading

U.S. Tax Court Issues Opinion on Filing False Returns

Dollar With Clock

U.S. Tax Court Issues Opinion on Filing False Returns Falsifying a tax return can lead to big penalties. Not only can you be ordered to pay the full tax amount owed plus interest, but you can also be ordered to … Continue reading

Nevada IRS Office Locations and Appointment Scheduling Tips

Woman Writing And Money By Her Side.

Nevada IRS Office Locations and Appointment Scheduling Tips If you have received a letter from the IRS notifying you that you are being audited, or if you have another tax issue that needs more in-person discussion rather than trying to … Continue reading

United States Tax Court Issues Opinion Denying Business Expense Deductions and COGS for a California Marijuana Dispensary

A Man Checking A Document With A Magnifying Glass: United States Tax Court Issues Opinion Denying Business Expense Deductions and COGS for a California Marijuana Dispensary

United States Tax Court Issues Opinion Denying Business Expense Deductions and COGS for a California Marijuana Dispensary On December 20, 2018, The United States Tax Court issued a new opinion regarding the federal taxation of state regulated marijuana businesses, and … Continue reading

United States Tax Court Issues Opinion on Accuracy-Related Penalties for Marijuana Businesses

Marijuana Businesses blog title: Tax Court Issues Opinion on Accuracy-Related Penalties Under Section 6662

United States Tax Court Issues Opinion on Accuracy-Related Penalties for Marijuana Businesses On November 29, 2018, The United States Tax Court issued an opinion providing further guidance to state regulated marijuana businesses on the issues of business deductions, cost of … Continue reading

United States Tax Court Issues Opinion Updating Case Law for State Sanctioned Marijuana Businesses

Marijuana Businesses

United States Tax Court Issues Opinion Updating Case Law for State Sanctioned Marijuana Businesses On November 29, 2018, The United States Tax Court issued an opinion providing further guidance to state regulated marijuana businesses on the issues of business deductions, … Continue reading

IRS Changes to Voluntary Disclosure Procedures

Irs Changes To Voluntary Disclosure Procedures

IRS Changes to Voluntary Disclosure Procedures Individuals and corporations alike have long conducted business or invested their money overseas as a means to try to avoid tax liability here in the United States. They figure that the IRS can’t monitor … Continue reading

Tax Penalties and Why You Should Pay on Time

Tax Penalties and Why You Should Pay on Time No one likes paying their taxes – well, you’d be hard pressed to find someone who openly admitted that they loved paying taxes, anyway – but we all have to pay … Continue reading

3 Ways to Find Out What the IRS Has on You

3 Ways to Find Out What the IRS Has on You You should file a tax return every year that you work or have other income to report. While you may only keep those tax returns or associated documents for … Continue reading

Negotiating Payment Plans with the IRS

Negotiating Payment Plans with the IRS A lot of people look forward to a nice tax refund at the end of the year, but some of us are unfortunate enough to owe the IRS instead. Some people miscalculate their tax … Continue reading

When is a Penalty Really a Penalty?

When is a Penalty Really a Penalty? Section 72(t)(1): Is it a Tax or a Penalty? Under Internal Revenue Code (IRC) section 6751(b), “No penalty under [the I.R.C.] shall be assessed unless the initial determination of such assessment is personally … Continue reading

When Does Tax Litigation Require the Assistance of a Business Firm?

When Does Tax Litigation Require the Assistance of a Business Firm? Much like doctors, lawyers often specialize in different fields. As one would not go see a heart surgeon for a broken leg, one should not see a divorce lawyer … Continue reading

How Bankruptcy Affects Tax Liens And Repayment Schedules

How Bankruptcy Affects Tax Liens and Repayment Schedules Taxes take a huge chunk out of our incomes. Some of us might try to mitigate that burden by adjusting our deductions so we get a bigger paycheck. We hope to minimize … Continue reading

United States Tax Court Hands IRS Another Win Against Risk-Pooled Small Captives

United States Tax Court Hands IRS Another Win Against Risk-Pooled Small Captives On June 18, 2018, the United States Tax Court issued an opinion upholding the IRS’ notice of deficiency against Reserve Mechanical Corp., f.k.a. Reserve Casualty Corp. (Reserve), a … Continue reading

Tenth Circuit Upholds IRS’ Application of Section 280E Denying Business Expense Deductions to Medical Marijuana Dispensaries and References Sessions Memo, Rescinding the Cole Memo

IRS Section 280E

Tenth Circuit Upholds IRS’ Application of Section 280E Denying Business Expense Deductions to Medical Marijuana Dispensaries and References Sessions Memo, Rescinding the Cole Memo Over half of the country’s fifty states and the District of Columbia have legalized medical or … Continue reading

When You Need a Tax Litigation Firm Instead of a Commercial Litigation Firm

When You Need a Tax Litigation Firm Instead of a Commercial Litigation Firm Running a business brings with it a fair number of risks. You risk loss and failure every day if the market turns or you make the wrong … Continue reading

United States Supreme Court Issues Opinion Expanding the Reach of States to Collect Sales Tax from Online Retailers

Collect Sales Tax from Online Retailers

United States Supreme Court Issues Opinion Expanding the Reach of States to Collect Sales Tax from Online Retailers Americans love to shop on-line. Lured by the convenience of shopping from home, competitive prices, and wide selection, on-line shopping has become … Continue reading

US Tax Court Issues Opinion on the Deductibility of Business Expenses for a Colorado Medical Marijuana Dispensary

US Tax Court Issues Opinion on the Deductibility of Business Expenses for a Colorado Medical Marijuana Dispensary Thirty states and the District of Columbia currently have laws broadly legalizing marijuana in some form. Most of these states have decriminalized the … Continue reading

Bipartisan Changes Slated to Redesign IRS

IRS Lawyer

Bipartisan Changes Slated to Redesign IRS Big changes could be in store for the IRS if a legislative package that is currently receiving bipartisan support passes through Congress. Over the past year and a half, lawmakers have sought information from … Continue reading

Passport Actions Under Section 7345

Passport Actions Under Section 7345

Passport Actions Under Section 7345 The Internal Revenue Service issued new guidance for handling passport actions related to tax debts this month. In 2015, the Fixing America’s Surface Transportation Act was passed, and it ruled that the State Department must … Continue reading

IRS Announced End to Offshore Voluntary Disclosure Program in September 2018

Tax Lawyer

IRS Announced End to Offshore Voluntary Disclosure Program in September 2018 Taxpayers with undisclosed foreign earnings or assets will soon run out of time to share that information with the Internal Revenue Service. The Offshore Voluntary Disclosure Program was introduced … Continue reading

Nevada Marijuana Businesses and Federal Income Tax Challenges Regarding Business Expense Deductions

Nevada Marijuana Businesses and Federal Income Tax Challenges Regarding Business Expense Deductions

Nevada Marijuana Businesses and Federal Income Tax Challenges Regarding Business Expense Deductions In 2001, the Nevada Legislature decriminalized the sale and use of “medical” marijuana. Since then, the Nevada marijuana industry has been thriving. In the fall of 2016, Nevada … Continue reading

IRS’s Gaming Industry Tip Compliance Program

IRS’s Gaming Industry Tip Compliance Program

IRS’s Gaming Industry Tip Compliance Program Las Vegas is an international, first-class, tourist destination. As the city has matured, Las Vegas now hosts some of the finest celebrity-run restaurants and bars. Tourism and gaming drive the Las Vegas economy, and … Continue reading

IRS Posts Notice on Foreign Tax Guidelines, Says It Plans to Release More Information

IRS Posts Notice on Foreign Tax Guidelines, Says It Plans to Release More Information

IRS Posts Notice on Foreign Tax Guidelines, Says It Plans to Release More Information A lot changed with the Trump tax plan approved at the end of last year, and many individuals and businesses are scrambling to figure out how … Continue reading

The Banking, Cash, and Tax Challenges Confronting Nevada Marijuana Businesses

The Banking, Cash, and Tax Challenges Confronting Nevada Marijuana Businesses

The Banking, Cash, and Tax Challenges Confronting Nevada Marijuana Businesses Nevada voters approved “recreational” marijuana in the fall of 2016 through a ballot initiative dubbed “Question 2,” and the official grand opening of the retail marijuana market began on July … Continue reading

IRS Urges Travelers Requiring Passports to Pay their Back Taxes or Enter into Payment Agreements

IRS Urges Travelers Requiring Passports to Pay their Back Taxes or Enter into Payment agreements

IRS Urges Travelers Requiring Passports to Pay their Back Taxes or Enter into Payment Agreements If You Plan to Travel with a Passport, You Better Pay Your Back Taxes or Get a Payment Plan. You likely already know that there … Continue reading

New Tax Law Regarding Spousal Maintenance

New Tax Law Regarding Spousal Maintenance Trump’s new tax plan has made big changes for people across the political and socioeconomic spectrum. One change that hasn’t gotten as much news coverage affects more than 600,000 Americans who pay spousal support, … Continue reading

How to Report Gains and Losses on Bitcoin and Other Cryptocurrency

How to Report Gains and Losses on Bitcoin and Other Cryptocurrencies

How to Report Gains and Losses on Bitcoin and Other Cryptocurrency Bitcoin is no longer the theoretical money of the future. Plenty of people are trading in Bitcoin and using it to pay for everything from coffees to furniture. Some … Continue reading

What Will the IRS Do to Enforce Collection?

What will the IRS do to enforce collection?

What Will the IRS Do to Enforce Collection? You can’t ignore a bill from the IRS the way you might be able to ignore a bill from the power company. The IRS won’t report you to the credit bureau and … Continue reading

5 Milestones on the Way to Tax Reform

5 Milestones on the way to tax reform

5 Milestones on the Way to Tax Reform President Trump has promised major tax reform since before he was even elected, but so far, no tax bill has been passed. However, we seem closer than ever to having some concrete … Continue reading

How Trumps New Tax Plan Will Affect You

How Trumps new tax plan will affect you

How Trumps New Tax Plan Will Affect You Donald Trump promised big tax reform when he was on the campaign trail, and he released a preliminary outline of his plan during this first 100 days, but he has not introduced … Continue reading

Obtaining an Installment Payment Agreement When You Owe Taxes to the State of Nevada

Obtaining an installment payment agreement when you owe taxes to the State of Nevada

Obtaining an Installment Payment Agreement When You Owe Taxes to the State of Nevada Although Nevada taxpayers can breathe a sigh of relief that they do not owe a state income tax, the Nevada Department of Taxation still collects and … Continue reading

Lessons to Learn from Professional Athletes’ Tax Troubles

Lessons to Learn from Professional Athletes’ Tax Troubles Professional athletes and income tax troubles: in recent years, the two have gone hand in hand. Las Vegas’s own Floyd “Money” Mayweather is currently embroiled in a United States Tax Court battle … Continue reading

Arizona and the IRS Contracting Debt Collection Companies

Arizona and the IRS contracting debt collection companies

Arizona and the IRS Contracting Debt Collection Companies You can’t always pay your tax bill on time. Sometimes, you end up owing more than you expected, and you’re blindsided by the bill come April. Other times, you know what’s coming, … Continue reading

What to Do if Your Tax Return Seems Wrong

What to do if your tax return seems wrong

What to Do if Your Tax Return Seems Wrong You file your taxes and send off a small check for what you owe. Or maybe you expect to get a little back, but not much. Then you’re surprised when you … Continue reading

Codes of Conduct for Tax Professionals

Codes of Conduct for Tax Professionals Tax professionals are bound by a code of ethics and laws governing their practice. When you hire an account, a tax law lawyer in Glendale, or some other tax professional, you can feel confident … Continue reading

What is Being Done to Reform the U.S. Tax Code?

what is being done to reform the US tax code

What is Being Done to Reform the U.S. Tax Code? With the election of a new president, there has been a lot of talk about shaking things up. Republicans are in control of both houses of Congress, and there is … Continue reading

IRS Resources for Phoenix Businesses and Residents

IRS Resources for Phoenix Businesses and Residents

IRS Resources for Phoenix Businesses and Residents Understanding your tax obligations can be confusing. The tax code is enormous and complex, and there are always exceptions and addendums to consider. Working with a tax lawyer is the best way to … Continue reading

Will President Trump Put an End to Offshore Tax Havens?

Will President Trump Put an End to Offshore Tax Havens

Will President Trump Put an End to Offshore Tax Havens? During the presidential primaries last year, both Democratic hopeful Bernie Sanders and Republican Donald Trump promised to put an end to offshore tax havens. Sanders wanted to end the ability … Continue reading

Understanding the Different Notices from the IRS

Understanding the Different Notices from the IRS

Understanding the Different Notices from the IRS It’s the thing that no one wants to see when they open the mailbox: A letter from the IRS. The letter might actually be letting you know that you made a mistake on … Continue reading

Top 5 Resources for Tax Knowledge

Top 5 Resources for tax knowledge

Top 5 Resources for Tax Knowledge Unless you’re a CPA or a tax lawyer in Paradise Valley, you’re probably just as confused about taxes as the rest of us. The tax code is huge, and you can’t know it all. … Continue reading

How the Repeal of Obamacare Will Affect Taxation

How the Repeal of Obamacare Will Affect Taxation

How the Repeal of Obamacare Will Affect Taxation Now that the Electoral College has confirmed Donald Trump as our next president, many are looking forward to big changes come January. One of the top priorities for the Republicans, who control … Continue reading

Alternative Currency, The Dark Web, Bitcoin, Death, and Taxes

bitcoin dark web

Alternative Currency, The Dark Web, Bitcoin, Death, and Taxes As the era of technology is constantly changing to fit the needs of everyday people, probably one of the more unusual parts of life is changing all in the name of … Continue reading

What Changes in Tax Law Might We See Under President Trump?

what changes in tax law might we see under president donald trump

What Changes in Tax Law Might We See Under President Trump? Any time a new president is elected, there is concern about how taxes will change. Will taxes be raised or lowered for certain groups or across the board? Will … Continue reading

IRS Releases New ACA Reporting Forms

irs tax international revenue service

IRS Releases New ACA Reporting Forms The year is closing in on us quickly, and before you know it, it will be time to start getting all your paperwork in order to file your taxes. If you run a business … Continue reading

How to Protect Yourself When the IRS Files a Lien against You

irs files lien against you

How to Protect Yourself When the IRS Files a Lien against You Failing to pay your tax bill can lead to big penalties. You can have your wages garnished, lose any future tax refund, and have your assets levied. If … Continue reading

Department of Labor’s New Final Overtime Rule

overtime rule

Department of Labor’s New Final Overtime Rule If you have a salaried position, you well know that you can work 50 or 60 hours a week and not get paid a dime – and that’s perfectly legal. Whereas if you … Continue reading

What are IRS Whistleblowers?

irs whistleblowers

What are IRS Whistleblowers? You may have seen a movie or two where a “whistleblower” was at the core of some takedown of a corrupt company causing cancer by polluting the water or covering up the harmful side effects of … Continue reading

What is the Statute of Limitations in Federal Tax Cases?

statute of limitations in federal tax cases

What is the Statute of Limitations in Federal Tax Cases? You know that you need to hang onto copies of your tax returns and your relevant forms and receipts after you file each year, but you may wonder just how … Continue reading

How to Pay Taxes on Unsourceable Income

taxes unsourceable income

How to Pay Taxes on Unsourceable Income When you collect your paycheck, you know that Uncle Sam has a hand in that transaction. Not only are the taxes you owe automatically deducted from your pay, but you know that your … Continue reading

Rules of Conduct for IRS Auditors

conduct irs auditors silver law

Rules of Conduct for IRS Auditors Being audited by the IRS is one of the most terrifying experiences that many people can think of having. When you’re sitting across from that IRS auditor, the situation can seem even more intimidating. … Continue reading

When Can Overdue Corporate Taxes Lead to Personal Liability?

corporate taxes personal liability

When Can Overdue Corporate Taxes Lead to Personal Liability? Corporations are obligated to pay a number of taxes, including payroll taxes, sales and use taxes, and income taxes. If they fall behind or they fail to pay, the IRS will … Continue reading

Is My Offshore Tax Haven Illegal?

offshore tax haven silverlaw

Is My Offshore Tax Haven Illegal? We hear a lot about offshore accounts thanks to news stories about unethical politicians or companies and their corporate officers that have been charged with tax fraud. The stereotype is that people open up … Continue reading

IRS Launches More Rigorous e-Authentication Process

irs silver law

IRS Launches More Rigorous e-Authentication Process Identity theft is a growing threat in our increasingly connected society. While the Internet may make it easier to do things like pay bills or file our taxes, it also makes it easier for … Continue reading

Criminal Tax Evasion vs. Negligence

Criminal tax evasion Silver Law

Criminal Tax Evasion vs. Negligence Ignorance of the law is not a defense of the law. But ignorance of the law can show that there was no criminal intent. It can mean the difference between being found guilty of negligence … Continue reading

Section 530 Relief in Employment Tax Cases with the IRS

Employment tax cases.

Section 530 Relief in Employment Tax Cases with the IRS As a business owner, you have to manage a lot of complicated tax issues. It is important that you hire a qualified accountant or tax lawyer to help you manage … Continue reading

The Insider’s Guide to the Panama Papers

A guide to the Panama Papers by a tax attorney providing offshore account legal advice

The Insider’s Guide to the Panama Papers These days, there always seems to be some kind of leak that sheds light on highly classified activities that show us all just how the world really works. We keep learning more about … Continue reading

Arizona Legislature Introduces New Tax Amnesty Program

Arizona Legislature Introduces New Tax Amnesty Program

Arizona Legislature Introduces New Tax Amnesty Program Bad things happen to the best of us. We come up short one year because we didn’t work as much or because we got injured and missed a lot of work while racking … Continue reading

The Latest Government Efforts to Undermine Tax Evasion, Money Laundering and Corruption

The Latest Government Efforts to Undermine Tax Evasion, Money Laundering and Corruption Tax evasion doesn’t just cost the government — it costs us all. When businesses and people aren’t paying their fair share in taxes, the rest of us either … Continue reading

What is the Cohan Rule?

Our tax attorney Phoenix discusses The Cohan Rule

What is the Cohan Rule? You will pay a lot of money to run your business, including basic overhead like rent and utilities, as well as extras like flights to attend conferences or meals to entertain clients. Many of these … Continue reading

Read the rest of What is the Cohan Rule?

Are IRS Budget Cuts Decreasing Your Odds of Being Audited?

Are IRS Budget Cuts Decreasing Your Odds of Being Audited?

Are IRS Budget Cuts Decreasing Your Odds of Being Audited? Few things are as scary to many people as the prospect of being audited on their tax returns. The tax man is like the grown up version of the boogeyman. … Continue reading

How to Contest an IRS Tax Bill Successfully in Fountain Hills

We can help with the IRS

How to Contest an IRS Tax Bill Successfully Getting a notice from the IRS can be intimidating. You may receive a letter that the IRS thinks you failed to report income or that you erroneously claimed a deduction and that … Continue reading

The Most Important Cave Creek Tax Filing Changes You Need to be Aware of Right Now

The Most Important Tax Filing Changes You Need to be Aware of Right Now Every year, changes are made to the tax code that affects how you file. That may mean that a tax break is available for a temporary … Continue reading

Avoiding Innocent Spouse Relief from the Start

Problems from delinquent taxes

Avoiding Innocent Spouse Relief from the Start When you are married, you share everything. You share all the money you make, and you share the liability for any debts or taxes. That means that when your spouse gets snowballed by … Continue reading

Your Rights as a Taxpayer: The Arizona Taxpayer’s Bill of Rights

Your Rights as a Taxpayer: The Taxpayer's Bill of Rights

Your Rights as a Taxpayer: The Arizona Taxpayer’s Bill of Rights When most people think of taxes, they think about their obligations — what they have to pay and the fines and penalties they will face if they don’t. Most … Continue reading

How Does America Stack Up against Other Countries?

How Does America Stack Up against Other Countries? When new social programs are discussed, such as free health care or free college education, there is a lot of discussion about other places in the world that already offer these programs … Continue reading

Make Your Phoenix Tax Audit Fast and Painless with These Great Tips

Make Your Phoenix Tax Audit Fast and Painless with These Great Tips Everyone dreads the idea of getting an IRS audit. But if you find out that you are the subject of one, you can’t just bury your head in … Continue reading

Taxes and Your Fountain Hills Pension Payout

Taxes and Your Fountain Hills Pension Payout

Taxes and Your Fountain Hills Pension Payout Retirement is a double-edged sword. On the one hand, you can look forward to never having to work again and spending your days as you see fit. You are finally ready to just … Continue reading

How Omissions on Your Paradise Valley Tax Return Can Have the IRS Audit You for Years to Come

How Omissions on Your Paradise Valley Tax Return Can Have the IRS Audit You for Years to Come

How Omissions on Your Paradise Valley Tax Return Can Have the IRS Audit You for Years to Come An IRS audit is the stuff of nightmares. Most of us file our taxes every year in good faith, having included everything … Continue reading

These Tax Breaks May Have You Heading Straight for an Audit

These Tax Breaks May Have You Heading Straight for an Audit

These Tax Breaks May Have You Heading Straight for an Audit Audits don’t just happen to those who are trying to skirt the rules or engaging in suspicious behavior. Even if you file every form you are supposed to and … Continue reading

Can Delinquent Taxes Keep You from Obtaining or Retaining a Passport?

Can Delinquent Taxes Keep You from Obtaining or Retaining a Passport?

Can Delinquent Taxes Keep You from Obtaining or Retaining a Passport? Can Delinquent Taxes Keep You from Obtaining or Retaining a Passport? Learn how a new provision signed into law on Dec. 4 prohibits those who are seriously delinquent on … Continue reading

Strategies to Minimize the Risk of an Arizona Income Tax Audit

Strategies to Minimize the Risk of an Arizona Income Tax Audit

Strategies to Minimize the Risk of an Arizona Income Tax Audit Strategies to Minimize the Risk of an Arizona Income Tax Audit. Here are some strategies that may help minimize the risk of a tax audit. Phoenix, Arizona The words … Continue reading

Are Arizona Taxes “Fair?”

Are Arizona Taxes "Fair?"

Are Arizona Taxes “Fair?” Are Arizona Taxes “Fair?” Here’s some information about how Arizona compares to other states in terms of taxes. Phoenix, Arizona The only things said to be certain in life are death and taxes. Yet some high-profile … Continue reading

Where Does My Phoenix Tax Money Go?

Where do Arizona tax dollars go?

Where Does My Phoenix Tax Money Go? Where Do Phoenix Tax Dollars Go??! Here’s some interesting information on how those Phoenix tax dollars are distributed. Phoenix, Arizona You may moan about paying taxes — that is a pretty big chunk … Continue reading

How Silver Law Can Help Represent You in Phoenix Criminal and Civil Tax Litigation

How Silver Law Can Help Represent You in Phoenix Criminal and Civil Tax Litigation

How Silver Law Can Help Represent You in Phoenix Criminal and Civil Tax Litigation How Silver Law Can Help Represent You in Phoenix Criminal and Civil Tax Litigation! The attorneys at Silver Law PLC can review your case and help … Continue reading

The IRS Takes Tax Evasion Seriously — No Matter Who You Are!

The IRS Takes Tax Evasion Seriously -- No Matter Who You Are!

The IRS Takes Tax Evasion Seriously — No Matter Who You Are! The IRS Takes Tax Evasion Seriously — No Matter Who You Are! Working with a Scottsdale tax attorney can help you minimize the penalties you have to pay … Continue reading

2024 badge for Best Lawyers in USA 2023 badge for Best Lawyers in USA 2022 badge for Best Lawyers in USA 2021 badge for Best Lawyers in USA 2020 badge for Best Lawyers in USA 2019 badge for Best Lawyers in USA 2018 badge top-tier Scottsdale tax lawyers at Silver Law PLC best-law-firm-award-2017 Silver Tax Law best tax lawyers in America 2016 Silver Tax Law best tax lawyers in America 2015
Tax Litigation | Our Civil Tax Litigation Experience | OUR CRIMINAL TAX LITIGATION EXPERIENCE | TAX AUDIT REPRESENTATION | OUR AUDIT AND APPEALS EXPERIENCE
TAX COLLECTIONS | INNOCENT SPOUSE RELIEF | REPRESENTATIVE CLIENTS | FOREIGN TAX REPORTING/OFFSHORE VOLUNTARY DISCLOSURE