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Articles Posted in Tax Controversy

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AMT relief 2008

AMT relief in the 2008 Extenders Act I am writing to provide details regarding three key provisions in the “Tax Extenders and Alternative Minimum Tax Relief Act of 2008″ (the 2008 Extenders Act), which was enacted on Oct. 3, 2008. The provisions extend partial relief to individual taxpayers from the…

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Tax Relief Act 2008

Individual and business extenders and other relief provisions in the 2008 Extenders Act The “Tax Extenders and Alternative Minimum Tax Relief Act of 2008″ (the 2008 Extenders Act), which was enacted on Oct. 3, 2008, provides extensions for several popular tax breaks and the addition of several new relief provisions,…

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Trust Fund Recovery Penalty

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…

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PEO Payroll Tax Problem

Leader of $181 million payroll tax scheme admits guilt [United States v. Amodeo, DC FL, Case No. 6:08-cr-176-Orl-28GJK Frank Amodeo, the former head of Mirabilis Ventures Inc., has pleaded guilty to federal charges that he and his co-conspirators knowingly failed to remit payroll taxes to the IRS totaling between $172…

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IRS Harassment

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…

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Ike Tax Relief

Texas Hurricane Ike Victims Qualify for IRS Disaster Relief IR-2008-107, Sept. 18, 2008 WASHINGTON — Texas taxpayers who were adversely affected by Hurricane Ike qualify for tax relief from the Internal Revenue Service, including the postponement of tax filing and payment deadlines until Jan. 5, 2009. Following the hurricane’s landfall…

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LLC Wage Levy

IRS explains how to collect from sole member of LLC law firm Chief Counsel Advice 200836002 In Chief Counsel Advice (CCA), IRS has concluded that a levy served on a limited liability company (LLC) will attach to property or rights to property belonging to the LLC’s sole owner. He practiced…

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WHFIT & WHMT Tax Relief

IRS provides WHFIT penalty relief for 2008 and WHMT reporting relief for 2007 Notice 2008-77, 2008-40 IRB In a Notice, IRS has informed trustees and middlemen of widely held fixed investment trusts (WHFITs) that it will not assert penalties under Reg. § 1.671-5(m) (dealing with WHFIT reporting rules) for calendar…

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1031 Exchange New Ruling

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.…

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Avoiding hobby loss restrictions

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…

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