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…
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…
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…
Year end planning moves that optimize enhanced election to expense business property Thanks to the Stimulus Act of 2008, most small businesses, and even moderate-sized businesses that don’t have huge capital equipment needs, may be able to claim a full Code Sec. 179 expensing deduction for the cost of business…
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…
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…
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…
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…
LLC may receive continuous wage levy on owner Chief Counsel Advice 200835030 A new IRS Chief Counsel Advice (CCA) says that a limited liability company (LLC) may be required to honor a continuous wage levy on salary and wage payments to its sole owner. [Note: The CCA may not be…