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Articles Posted in Tax Controversy

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Fiduciary Estate Trust Tax Resolution – Irrevocable Grantor Trust

Grantor’s power to substitute trust property didn’t trigger inclusion in estate – Rev Rul 2008-22, 2008-16 IRB 796 Mike Habib, EA myIRSTaxRelief.com A new revenue ruling concludes that the corpus of an irrevocable trust that a grantor created during life is not includible in his gross estate under Code Sec.…

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Farmers tax problems – Farmers Tax Relief Help

Offsets in Senate Finance’s farm bill include Schedule F loss limits, optional self-employment tax, and information reporting Mike Habib, EA MyIRSTaxRelief.com On April 18, the Senate Finance Committee conferees on the farm bill announced $2.4 billion of reforms/offsets – “double the reforms in the House or Senate bills alone” –…

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Federal tax lien – IRS proposed priority

IRS proposed regs would update federal tax lien priority provisions for holders of security interests Preamble to Prop Reg 04/16/2008, Prop Reg § 301.6323(b)-1, Prop Reg § 301.6323(c)-2, Prop Reg § 301.6323(f)-1, Prop Reg § 301.6323(g)-1 Mike Habib, EA myIRSTaxRelief.com IRS has issued proposed regs on the priority of federal…

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IRS enforcement in tax collection and tax audit activity is on the rise

IRS Oversight Board Annual Report 2007 is now available – see more details below Mike Habib, EA myIRSTaxRelief.com As you can see from the report below, the IRS places “<span as their TOP priority, that will involve enforcement of their collection activity of back taxes owed, and enforcement of their…

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Truck Drivers – Trucking Company Tax Problem Resolution

IRS acquiesces to TLC Leasing – explains meals deduction limit in employee leasing setting Rev Rul 2008-23, 2008-18 IRB TRUCKER TAX RELIEF & TRUCKER TAX PROBLEM RESOLUTION Trucking Tax & Accounting: Back Taxes – Unfiled delinquent tax returns – IRS & State audits – Messy books / accounting Mike Habib,…

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US employers and foreign employees tax problem

IRS rules that withholding exceptions for employees in foreign country don’t apply – Chief Counsel Advice 200814010 Mike Habib, EA myIRSTaxRelief.com In Chief Counsel Advice (CCA), IRS has held that a U.S. employer had to withhold on wages it paid to employees working in a foreign country. The withholding exception…

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IRS Tax Penalty – How to abate and avoid penalties

Avoiding IRS Tax Penalties and the Tax Gap Mike Habib, EA myIRSTaxRelief.com IRS — The Internal Revenue Code imposes many different kinds of penalties, ranging from civil fines to imprisonment for criminal tax evasion. If you do not file your return and pay your tax by the due date, you…

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Intellectual property contribution tax problem resolution

Final regs detail donee’s filing requirements for qualified intellectual property contributions T.D. 9392, 04/04/2008; Reg. § 1.6050L-2 Mike Habib, EA MyIRSTaxRelief.com IRS has issued final regs explaining the information return requirements for donees receiving net income from qualified intellectual property contributions made after June 3, 2004. Background. A taxpayer’s deduction…

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