Transfers to LLC were not includable in decedent’s estate Estate of Mirowski, TCMemo 2008-74 The Tax Court has held that assets the decedent transferred to a family limited liability company (LLC) shortly before she died were not includable in her gross estate under Section 2036(a). Facts. The decedent’s husband was…
Innocent spouse relief granted despite ex-husband’s objection Bishop, TC Summary Opinion 2008-33 The Tax Court agreed with the IRS and, over the objection of the taxpayer’s ex-husband, held that the taxpayer was entitled to equitable relief under Section 6015(f) from her husband’s tax underpayments. Facts. The taxpayer married in 1982,…
New bill seeks to reduce worker misclassifications H.R. 5804, 4/15/08 [Taxpayer Responsibility, Accountability, and Consistency Act of 2008] Rep. James McDermott (D-Wash) has introduced legislation that would revise employee vs. independent contractor rules and increase information reporting penalties The legislation is called the “Taxpayer Responsibility, Accountability, and Consistency Act of…
<span [Audit Report No. 2008-30-095]: Fiscal year 2007 marked another period of improvement in IRS’s compliance activities, continuing an eight-year period of upward trends in such endeavors, the Treasury Inspector General for Tax Administration (TIGTA) said in a new audit. Many enforcement activities continued to increase despite a slight reduction…
Tax Problem Solver – Why You Need Professional Help Tax problems come in different forms; IRS tax problems, State tax problems, and Sales tax problems. Tax authorities are constantly increasing their tax enforcement efforts through tax collection and tax audit. When taxpayers receive the dreaded tax notice that their tax…
TIGTA study finds modest audit rate increase for C corps but marked increase for passthroughs ( S Corps) Trends in Compliance Activities Through Fiscal Year 2007, TIGTA Reference Number 2008095 A recently released TIGTA (Treasury Inspector General for Tax Administration) report reveals that despite a slight uptick in FY 2007,…
TIGTA issues statutory review of IRS compliance with legal guidelines when issuing levies [ Audit Report No. 2008-30-097 ]: During the process of issuing levies, IRS has been complying with legal guidelines regarding proper notification and the protection of taxpayer rights, the Treasury Inspector General for Tax Administration (TIGTA) reported…
Houses passes legislation that would make sure certain government contractors pay employment taxes – Foreign shell companies payroll tax problems Mike Habib, EA myIRSTaxRelief.com The House of Representatives has passed legislation [H.R. 5719, Sec. 18, 4/15/08] proposed by Representatives Brad Ellsworth (D-Ind.) and Rahm Emanuel (D-Ill.) that seeks to end…
District court allows $60 million of income to be offset by Son-of-Boss shelter Sala v. U.S. (DC Co 4/22/08) 101 AFTR 2d ¶ 2008720 Mike Habib, EA myIRSTaxRelief.com A district court has allowed an individual to offset $60 million of compensation income with losses from a Son-of-Boss transaction. Facts. Carlos…
Payments made by retailer in connection with sales promotion weren’t taxable – PLR 200816027 Mike Habib, EA myIRSTaxRelief.com The IRS has privately ruled that payments made by a retailer in connection with a sales promotion were nontaxable purchase price adjustments and they weren’t subject to reporting or withholding. Facts. Taxpayer,…