Double Tax on Inter-Company Transfers

There are those who make things happen. They are usually the ones doing what it takes even when doing so is difficult, tiring, and draining. They are the ones that often make personal sacrifices and take risks to succeed. They are the ones that had the luck or grit to stick with something to see…

IRS Documentation for Travel Expenses

Business travel expenses are deductible. These are expenses for business trips and work trips, such as car and truck expenses, airfare and hotels and lodging. It can also include travel meals. Those looking to deduct business trip expenses are running a risk as the IRS frequently disallows these expenses on audit. It does so even…

Adequate Dislcosure to Avoid Six Year IRS Statute

Adequate Dislcosure To Avoid Six Year Irs Statute

The IRS has a limited period of time to conduct audits. It often fails to finish the audit within this period of time. There are even instances where the IRS does not even start the audit until after this time period has passed. This raises tough questions for taxpayers. Taxpayers expect some finality with their…

What is a Repetitive IRS Audit?

What Is A Repetitive Irs Audit?

When it comes to the IRS and audits, there are times when a taxpayer may feel like they can’t win. This is often true. If you have been reading this site for some time, you may recall our article involving Five Audits in Ten Years and the court concluding that this many audits in such…

Getting the IRS to Act Timely

Getting The Irs To Act Timely

There are quite a few avenues available to resolve tax disputes with the IRS. We have previously considered these options for resolving tax cases in a prior article. The number of avenues available can make it difficult to navigate the IRS bureaucracy. This plus the slow pace at which the IRS works makes it very…

Can the IRS Waive Compliance With Tax Rules?

Can The Irs Waive Compliance With Tax Rules?

What happens if you make a technical foot fault while working with the IRS? Say you miss a deadline or a filing requirement. Can the IRS waive compliance with the deadline or requirement? IRS personnel will often say that they cannot. But in reality, the IRS can waive most procedural requirements. The authority for this…

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Categorized as IRS Audits

Does an IRS Audit Waive a Defect in Tax Return?

Does An Irs Audit Waive A Defect In Tax Return?

When it comes to technicalities in the tax law, the failure to comply with some technicalities can be overcome. Others cannot. As a general rule, the courts evaluate tax disputes involving technicalities based on the policy underlying the technicality versus fairness for requiring strict compliance. If the policy for the technicality is important, the court…

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Categorized as IRS Audits

Electing Out of the Partnership Audit Regime

Electing Out Of The Partnership Audit Regime

When it comes to income taxes and IRS audits, there are a lot of procedural rules that are counter-intuitive. Even if one thinks they are half-baked, the rules are the rules. They can have serious consequences. The centralized partnership audit regime is an example. Tax advisors often instruct their clients to elect out of the…

Can You Rely on IRS Statements?

Can You Rely On Irs Statements?

If you ask someone a direct question and the person responds with incorrect information, is the person bound by their misrepresentation? This raises questions of “estoppel,” which apply to most litigants. But does it apply to IRS employees who make a misrepresentation? Put another way, can you rely on statements by IRS representatives? The court…

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When an IRS Agent Makes a Misrepresentation

When An Irs Agent Makes A Misrepresentation

IRS agents interact with taxpayers. In doing so, they make misrepresentations as any other human does. Some are unintentional and some are intentional. But what is a taxpayer to do if the IRS agent makes a misstatement and it negatively impacts the taxpayer? The McRae v. Commissioner, T.C. Memo. 2019-163, case touches on this issue.…

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Categorized as IRS Audits