Valuing property for tax purposes is complex and can be a critical issue as it can result in significantly higher or lower taxes. The Garwood v. Commissioner, T.C. Memo. 2004-195, case offers a fascinating example of the challenges and pitfalls involved in valuation, particularly in the context of tax court cases. This case involved the…
Tax Articles
The Sentencing Guideline Point System for Tax Crimes
Transactions can have a number of consequences. This includes criminal tax consequences–such as an IRS audit that goes criminal. Understanding criminal sentencing guidelines and how they apply to tax cases or could apply is part of the value the tax attorney brings to transactions. Tax-related crimes, such as tax fraud, can lead to criminal charges…
Congress Changes the IRS Offer in Compromise
The IRS offer in compromise (“OIC”) program is a tax resolution option offered by the IRS to help taxpayers who are unable to pay their full tax liability. It allows eligible taxpayers to settle their tax debts for less than the full amount owed, based on their financial situation and ability to pay. The OIC…
Lessons Learned from Colorado’s Taxpayer Bill of Rights
Taxpayers’ Bills of Rights (TABORs) prevent state governments from increasing taxes or spending revenue growth without first obtaining voter approval. Several states are poised to adopt state TABORs in the near future. The State of Colorado adopted a TABOR in 1992. There are a number of lessons that other states can learn from Colorado’s TABOR…
The Three Offer in Compromise Options
The IRS Offer in Compromise program presents taxpayers with a viable option to settle tax debts for an amount less than what is owed. The program has been around for quite some time and, as with everything when it comes to the IRS, there are a number of nuances. The IRS has developed numerous procedures…
Tax Liability Review by Tax Court Limited
The collection due process hearing law has provided taxpayers with another avenue for challenging their underlying tax liabilities. With this option, taxpayers can let the IRS assess the additional tax or penalties and then wait for the IRS to attempt enforced collection for the balance. They can then file a collection due process hearing request…