Tax fraud is a serious crime that can result in harsh criminal tax penalties, including fines and imprisonment. However, the specific sentence for a tax crime varies depending on the case and the judge presiding over it. In cases of tax fraud, the discretion of the judge can play a crucial role in determining the…
Category: Tax Procedure
Tax Procedure
From IRS audits and appeals to tax litigation and penalties, our tax attorneys can help you navigate the tax procedure landscape with confidence. Give us a call to see how we can help, (713) 909-4906.
U.S. Tax Court Petition Date is Absolute
When it comes to tax issues, deadlines are a crucial aspect of the process. However, the strictness and inflexibility of these deadlines can often seem absurd, especially given the consequences for the government. Does it truly matter if the IRS receives a tax return a day late, especially if they don’t even plan on looking…
Prisoners Filing False Tax Returns
If you are reading this, you probably have a job or business or are an employee and put in long hours at work. This may mean time away from your friends and family and not being able to pursue things that give you purpose. We make these sacrifices to earn a living. To provide for…
The IRS Summons Enforcement Hearing
The IRS has quite a few powers to encourage taxpayers to cooperate. The IRS summons is the most powerful tool the IRS has in its arsenal. While the taxpayer may not agree that the underlying tax is even owed, they still have to comply with the IRS’s summons. The recent United States v. Battle, 213…
New IRS Tax Lien Regulations Issued
When the IRS places a lien on someone’s property, it means that the taxpayer owes the IRS back taxes. The lien serves as a legal claim against the taxpayer’s property, and it can negatively impact their financial and professional life. One of the most significant consequences of an IRS tax lien is the damage it…
The IRS’s TEFRA Partnership Challenges
Taxpayers often complain about how difficult the tax code and law are. And they are correct to do so, as the complexity generally favors the IRS. It leaves taxpayers in the position of having to wait for an IRS audit only to find that all of their efforts to comply and do their taxes correctly…
IRS Cannot Abate Interest on Employment Taxes
The IRS has a track record of not acting timely. Its failures in this regard are frequent and, sadly, they are expected. The bar has been set so low that we actually expect the IRS to go slow. This can be extremely frustrating for taxpayers and it can even cost taxpayers a considerable amount of…
Congress Works on the IRS Informants Reward Program
The Tax Relief and Health Care Act of 2006 makes a number of changes related to the IRS informants reward program. This program has long been ridiculed for being ineffective and poorly administered. Even the U.S. Treasury Inspector General for Tax Administration has said so. The question is whether the sweeping changes will have any…
The Improved Frivolous Return Penalty
The Tax Relief and Health Care Act of 2006 has brought significant changes to the frivolous income tax return penalty under Section 6702. Until now, the low penalty amount and limited reach of this penalty meant that taxpayers did not have to worry about the consequences of filing frivolous tax returns. However, with the changes…
Taxpayers Cannot Record IRS Telephone Interviews in CDP Hearings
Sometimes it is nice to have a record of what transpired. This is true even if the recording is never used. Just the fact that the recording is being made, and everyone is aware that it is being made, can change the tone and substance of the meeting. The law allows taxpayers to record meetings…