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
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 tax audit activity. The IRS must strive to achieve the standard of “great” performance and settle for nothing less, the IRS Oversight Board said in its latest annual report. The board called for “breakthrough” agency performances in four areas – taxpayer service, enforcement, human capital and information technology. For example, to enhance customer service, IRS must continually assess taxpayer needs and implement education and outreach services tailored to the needs of specific taxpayer groups, the board said. IRS also must apply the results of its research efforts to improve its enforcement activity. In addition, the agency must address the loss of unique skills and institutional knowledge that results from the normal retirement rate of some 4,000 employees annually. “The board has challenged the IRS to rise to an unprecedented level of performance in all parts of its mission,” said Paul Cherecwich, chairman of the board. “It will not be easy and there are no givens. But the board firmly believes that today’s IRS is up to the task and the end results will be worth the journey and the hard work.” The annual report can be found at http://www.ustreas.gov/irsob/reports/2008/IRSOB_Annual-Report_2007.pdf
No refund suit is allowed in the absence of a timely claim filed with IRS
U.S. v. Clintwood Elkorn Mining Co., (S Ct 4/15/2008) 101 AFTR 2d ¶ 2008696
Mike Habib, EA
myIRSTaxRelief.com
The Supreme Court, reversing the Court of Appeals for the Federal Circuit, has held that the plain language of Code Sec. 7422(a) and Code Sec. 6511 requires a taxpayer seeking a refund of a tax assessed in violation of the Export Clause of the U.S. Constitution, just as for any other unlawfully assessed tax, to file a timely administrative refund claim with IRS before bringing suit against the Government.
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
IRS Begins Focus on Foreign Athletes and Entertainers
The IRS recently launched an Issue Management Team focused
on improving U.S. income reporting and tax payment compliance by foreign athletes and entertainers who work in the United States. The initial focus is on those engaged in tennis, golf and music. These individuals and those associated with arranging their appearances in the U.S. and managing their financial affairs are typically high income individuals. Because of this, it is important to ensure proper tax reporting and payment.
Failure to follow IRS procedure prevented use of longer NOL carryback
Tualatin Valley Builders Supply, Inc. v. U.S. 101 AFTR 2d ¶ 2008688
IRS rules that withholding exceptions for employees in foreign country don’t apply – Chief Counsel Advice 200814010
Foreclosure Prevention Act of 2008 – S
enate passes housing stimulus bill
Mike Habib, EA
myIRSTaxRelief.com
On Apr. 10, the Senate by a vote of 84 to 12 approved H.R. 3221, the “Foreclosure Prevention Act of 2008,” the Senate housing stimulus bill. Before final passage of the bill, the Senate approved an amendment offered by Senator John Ensign (R-NV) that would extend various clean energy production incentives.
Memo explains how state property tax credits are taxed and reported – Chief Counsel Advice 200814022
Tax Relief Blog