The IRS recently announced that it will be launching a system to allow “tax professionals” to apply online for tax payment agreements or tax installment agreements for their clients. IRS Online Pro’s & Cons While this is a step in the right direction, it does present yet another opportunity to consider whether the IRS should…
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.
Deposits vs. Payments: How to Pay the IRS
Paying taxes is an essential part of being a responsible citizen. The IRS has specific rules and procedures for taxpayers to follow when submitting their tax payments. However, many taxpayers may not be aware that there is a difference between making a payment and a deposit when paying the IRS. The two are not the…
Missing Form 1099 May Establish Reasonable Cause
In general, if you do not receive a Form 1099 to report income to you and you omit it from your tax return, you may still be liable for penalties if the IRS later notices the issue and makes an adjustment. This is because taxpayers have a responsibility to report all their income, regardless of…
IRS Looks at Improving Informants Rewards Program
The IRS using paid informants to identify noncompliant taxpayers may seem controversial, but it has not generated much controversy as the program has been poorly administered. In this article, we will discuss the IRS Informants Rewards Program, its eligibility requirements, and the recent changes to the program. About the IRS Whistleblower Program The IRS Whistleblower…
New Offer in Compromise Legislation
As discussed in a previous post, Congress has been toying with making changes to the IRS offer-in-compromise program. These changes were eventually included in the “Tax Increase Prevention and Reconciliation Act,” which President Bush signed into law on May 17, 2006. The new rules apply to offers in compromise filed 60 days after the date…
Prisoner Entitled to Convenient CDP Hearing
There are quite a few rights taxpayers have, that are disregarded by the IRS, and there is no remedy when it happens. As noted in Butti v. Commissioner, T.C. Memo. 2008-82, the IRS collection due process hearing can be one of those circumstances. The case involves a collection due process hearing, which is a legal…
Can the IRS Re-Assess Tax to Fix Its Own Error?
When a taxpayer makes an error on their tax return or fails to make timely payments to the IRS, it can result in additional tax, penalties, and even interest owed. This can be the case even if the taxpayer is just one day late or if the applicable tax laws are unclear or highly complex.…
Drug Addiction Excuse for Filing Tax Return Late?
Drug addiction is a medical condition. It can be a very serious and life-altering medical condition. This begs the question as to whether drug addiction or migraines be an excuse for filing a tax return late or for abating late filing penalties. The court addresses this in Jordan v. Commissioner, T.C. Memo. 2005-266, for a…
Can the IRS be Efficient and Effective at the Same Time?
The Internal Revenue Service (“IRS”) is responsible for assessing and collecting taxes, enforcing tax laws, and helping taxpayers comply with our laws. There are a number of varying policies and circumstances that the IRS has to get involved in while administering the tax system. This can put the IRS in odd positions. There can be…
Tax Aspect of the Bankruptcy Abuse Prevention & Consumer Protection Act
The Bankruptcy Abuse Prevention and Consumer Protection Act (“BAPCPA”) was enacted by Congress to address the perceived bankruptcy abuses. The law made significant changes to the bankruptcy code, including new eligibility requirements, mandatory credit counseling, and the creation of the means test. While BAPCPA was primarily aimed at addressing bankruptcy-related issues, it also had significant…