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Articles Posted in Tax Controversy

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Payroll Tax Relief

Roundup of recent employment tax related cases of interest Mike Habib, EA Tax Relief & Tax Problem Resolution Federal courts have recently issued rulings on: (1) whether medical residents may qualify for the student FICA exception, (2) whether an employee’s embezzlement was reasonable cause for failing to remit withholding taxes,…

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1031 Tax Problem

Like-kind-exchange related party rule triggered gain recognition despite use of qualified intermediary Ocmulgee Fields, Inc. (2009) 132 TC No. 6 Mike Habib, EA Tax Relief Services The Tax Court has held that a taxpayer could not avoid the like-kind-exchange related-party rule by using a qualified intermediary. The taxpayer had to…

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IRS Tax Help for Expats

Adverse conditions may allow certain U.S. citizens to claim foreign earned income and housing cost exclusions [Rev Proc 2009-22]: Individuals who were forced to leave certain foreign countries in 2008 because of adverse conditions may still qualify as bona fide residents of that country for purposes of the IRC §911…

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Subsidiary employment tax problem

Subsidiary’s employment tax liability cannot be collected from the parent corporation [Chief Counsel Advice 200913052]: The IRS Office of Chief Council has expressed its opinion in a new Chief Council Advice (CCA) that the employment tax liability of a subsidiary corporation in a consolidated group cannot be collected from the…

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Offshore Tax Settlement

IRS announces settlement offer for those that voluntarily disclose unreported offshore income Mike Habib, EA Tax Relief & Tax Resolution Services IRS Commissioner Doug Shulman has announced what is in effect a settlement offer for those that voluntarily and timely disclose unreported offshore income. Those meeting the terms of the…

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IRS Levies on the rise despite the recession

IRS wage garnishment levy and IRS bank levy tax relief Collecting tax revenue in the face of recession has been – and will continue to be – a challenge for the IRS. There is an increase in the number of taxpayers unable to pay their back taxes due to loss…

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Solve Your 941 Payroll Tax Problems

Solve Your 941 Payroll Tax Problems It’s fairly common for businesses – no matter what size – to struggle with some sort of 941 tax issue or another. Even companies that use good payroll software to sort out their entire payroll related taxes are still prone to errors. The IRS…

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