Once is enough as far as collection of the trust fund recovery penalty is concerned Chief Counsel Advice 200838027 The IRS has issued a new Chief Counsel Advice (CCA) on the trust fund recovery penalty. The IRS notes that the CCA may not be used or cited as precedent. IRC…
TIGTA review finds small number of cases where IRS employees harassed taxpayers while attempting to collect taxes [Audit Report No. 2008-10-162]: In 2007, there were five cases involving Fair Tax Collection Practices (FTCP) violations for which an IRS employee received administrative disciplinary action, according to a recent audit by the…
IRS OKs use of one property to engineer a reverse and forward like-kind swap Chief Counsel Advice 200836024 In Chief Counsel Advice (CCA), IRS has given its blessing to the use of one property to engineer both a completed reverse like kind exchange and an attempted forward like kind exchange.…
Like many of us, you’ve probably dreamed of turning a hobby or avocation into a regular business. You won’t have any unusual tax headaches if your new business is profitable. However, if the new enterprise consistently generates losses (deductions exceed income), IRS may step in and say it’s a hobby–an…
IRS Tax Help by Mike Habib, EA UNFILED BACK TAX RETURNS Do you have back tax returns that are Unfiled? Are you missing the records and forms necessary to file your tax returns? I have the experience and procedures to help you in reconstructing the records necessary to file your…
IRS Fact Sheet reviews whether a hobby is actually a for-profit endeavor [Fact Sheet 2008-23]: Taxpayers must follow appropriate guidelines when determining whether an activity is engaged in for profit, such as a business or investment activity, or is engaged in as a hobby, IRS said in a new fact…
To disclose or not to disclose, that is the question. Hiding Income Offshore is not the way to go. Mike Habib, EA For years, offshore accounts have been a hot topic in popular culture and for the IRS; most recently Liechtenstein has been mentioned, however the IRS is interested in…
If It Seems Too Good to Be True, It Probably Is Tax Return Preparer Fraud Mike Habib, EA Dishonest tax return preparers can cause many problems for taxpayers who fall victim to their schemes. These scam artists make their money in a number of ways including skimming a portion of…
Yes, we are all fed up with the cost of fuel. No, I’m sorry to report, not everyone is eligible for the fuel tax credit. Fuel Tax Credit Scams Mike Habib, EA The IRS has recently added fraud involving the fuel tax credit to the list of frivolous tax claims…
Tiered discount allowed in real estate FLP gift tax case In Astleford, a memorandum decision, the Tax Court permitted a taxpayer to apply a tiered discount in the context of a family limited partnership owning interests in real estate. Facts. On 8/1/96, Mrs. Astleford formed the Astleford Family Limited Partnership…