Tax Blog


Improbable Position by IRS Sufficient to Impose Tax






The Transupport, Inc. v. Commissioner, No. 17-1265 (1st Cir. 2018) case involved evidence that was not sufficient to support imposing a penalty, but the same evidence was sufficient to hold the taxpayer liable for the tax. The case provides an …..
Th…


Improbable Position by IRS Sufficient to Impose Tax






The Transupport, Inc. v. Commissioner, No. 17-1265 (1st Cir. 2018) case involved evidence that was not sufficient to support imposing a penalty, but the same evidence was sufficient to hold the taxpayer liable for the tax. The case provides an …







IRS Summons Reaches Attorney’s Client Names






Communications with an attorney are generally protected from disclosure.  But what about client names?  And what power does the IRS have the power to force an attorney to disclose the names of his clients?  The court addressed this in U.S. …







IRS Summons Reaches Attorney’s Client Names






Communications with an attorney are generally protected from disclosure.  But what about client names?  And what power does the IRS have the power to force an attorney to disclose the names of his clients?  The court addressed this in U.S. …..

The post IRS Summons Reaches Attorney’s Client Names appeared first on Houston Tax Attorney.







Court Rejects the ‘Taking All Necessary Steps’ Defense to Penalties






If you take all of the steps to prepare and remit a tax return to the IRS except for placing it in the mail, is this sufficient to avoid a failure to timely file penalty?  There is case law suggesting …







Court Rejects the ‘Taking All Necessary Steps’ Defense to Penalties






If you take all of the steps to prepare and remit a tax return to the IRS except for placing it in the mail, is this sufficient to avoid a failure to timely file penalty?  There is case law suggesting …..

The post Court Rejects the ‘Taking All Necessary Steps’ Defense to Penalties appeared first on Houston Tax Attorney.







Misappropriated Money Subject to Tax, Even if No Criminal Violation






The proceeds of criminal activities are taxable income. Money that is embezzled from an employer is taxable to the embezzling employee. But what about money transferred between friends with the agreement that one of them will invest the funds, but …….







Misappropriated Money Subject to Tax, Even if No Criminal Violation






The proceeds of criminal activities are taxable income. Money that is embezzled from an employer is taxable to the embezzling employee. But what about money transferred between friends with the agreement that one of them will invest the funds, but …







About the IRS Certificate of Discharge






The IRS’s lien for unpaid taxes attaches to all property owned by the individual. This can prevent the individual from selling or transferring their property or refinancing the property. There are several potential remedies that can help in this situation. …







Can the IRS Collect from a Single-Member LLC?






When trying to settle a tax debt with the IRS or manage the collection process, there are often questions as to whether the IRS can collect from a legal entity owned by the taxpayer. This often comes up in the …