IRS Audits Tax Procedure

IRS Statistics for Audit and Enforcement Rates

While the IRS does not release many of the factors that it uses to identify taxpayers for tax audits, the IRS does release general statistics that can help gauge a taxpayer’s audit potential.¬†¬†These statistics help answer the question of “what are the chances of being audited?” IRS Audit Rates Looking at the most recent IRS […]

Federal Income Tax

An Example of How Our Tax Laws Favor the Wealthy

In my tax practice, I have noticed that the tax laws for issues that face my wealthy clients are often much more friendly than the tax laws for issues that face my not so wealthy clients. The most recent Vines v. Commissioner case and the Cowan v. Commissioner cases provide examples. Facts & Procedural On […]

Federal Income Tax Retirement Accounts Tax Tax Deductions

Part-Time Employee Not Entitled to Deduction for IRA Contribution

Taxpayers who participate in their employer’s retirement plan are not able to deduct contributions the taxpayer makes to their IRA retirement account. This is also true for taxpayers who are entitled to participate in their employer’s retirement plan, but choose not do so. In Colombell v. Commissioner, T.C. 2006-184, the court considered whether an employee […]

IRS Appeals IRS Audits Tax Procedure

The IRS’s New Appeals Arbitration Program

The IRS Office of Appeals provides a great forum for resolving IRS tax disputes.  While appeals settles a lot of cases, it doesn’t settle them all.  This is where the IRS arbitration program comes in.  It is for those close cases that almost settled, but didn’t.  The IRS recently released Revenue Procedure 2006-44, which sets out […]

IRS Debts Tax Procedure

Tax Resolution Firm Job Posting: The Industry Needs to be Regulated….

I thought that I would share with you this Craigslist post that one of my clients forwarded to me: TAX RESOLUTION ASSOCIATES ——————————————————————————– Tax resolution associates wanted for Boulder financial company. ATTENTION: YOU DO NOT HAVE TO HIT A $25k OR $30k FOR BONUS!!!!!!!!!!!We pay 15% at $15k, 20% at $20k and 25% at $25k. […]

Federal Income Tax

French Exempt Low Wage Employees from Payroll Taxes: Could it Work in the US?

It is always interesting to hear about how other countries address tax issues. Like the United States, the French government collected higher than expected tax revenues last year. Where the United States government opted to keep the tax revenues, the French government has proposed to use the tax revenues to exempt minimum wage employees who […]

IRS Interest Tax Procedure

Interest Abatement: What is a Ministerial Act?

The IRS is authorized to abate or remove interest where there is a ministerial act. Okay, so what does that mean? What is a ministerial act? The Beall vs. United States, 170 F. Supp. 2d 709 (E.D. Tex. 2001), case provides an opportunity to consider this question. Facts & Procedural History The Bealls were limited […]