Court Invalidates Longstanding Process to Challenge IRS Levy

If the IRS fails to mail or mails a notice to a taxpayer and uses the wrong address, should the taxpayer be faulted for missing the deadline set out in the IRS notice? The Seventh Circuit Court of Appeals says …..

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Court Considers Whether Moneygram is a Bank that Makes Loans

There are tax laws that provide significant tax advantages to banks. One of these laws allows banks to deduct capital losses against ordinary income. This allows banks to deduct losses immediately when others might have to carryover the loss to …..

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IRS Wage and Salary Levy Exemptions for 2017

The IRS recently issued Publication 1494, Tables for Figuring Amount Exempt From Levy on Wages, Salary, and Other Income – Forms 668-W(ACS), 668-W(c)(DO) and 668-W(ICS), for 2017.  This publication provides the amount of wage and salary that are exempt from …..

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Reportable Transaction Penalty Not Divisible, Full Payment Required to Bring Suit

Tax matters can be litigated in a number of different courts. One of the advantages of bringing suit in U.S. Tax Court is that the tax does not have to be paid prior to bringing suit. For tax matters litigated …..

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Can IRS Cure Defective Summons With Second Summons?

The administrative summons is one of the IRS’s primary tools for obtaining information from taxpayers and third parties. There are very few requirements that the IRS has to satisfy in issuing summones. In Maxcrest Limited v. United States, Case No. …..

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Lost IRS Notice Was Timely, Despite IRS Not Following Procedures

There are a number of dates that must be met when it comes to taxes. Many of these dates are triggered by some action by the IRS. This raises the question as to what happens if the taxpayer is not …..

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TIGTA Suggests IRS Follow Transfer Pricing Roadmap

Transfer pricing is and has been the most significant and difficult issue the IRS audits. The audits are typically closed with the IRS agents proposing unreasonably large adjustments and IRS appeals sustaining a very low percentage of the adjustments. The …..

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