The IRS is prohibited from disclosing taxpayer information to third parties. There are a number of exceptions. But when the laws are violated, the courts can and do award damages to taxpayers. In Ward v. United States, 973 F. Supp. 996 (Dist. Colo. 1997), the court found that the IRS had violated the law by…
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.
Can Bankruptcy Court Order IRS to Consider an OIC?
Have you ever found yourself in a situation where you were recognized as an expert, provided guidance or input on a matter, but then had a third party reach a different conclusion? If not, try to imagine yourself in such a situation. How would you react? Would you feel like your expertise had been undermined,…
U.S. Tax Court Violates It’s Own Rules
Do you know the feeling when you realize you are in a situation and you have no real remedy? If so, you probably also know the same feeling when you are in a situation where you are 100% right and there is a third party who is not. Most of us learn about these feelings…
Taxpayer Statements During Audit Admissible in Criminal Trial
When a civil tax case involves suspected criminal activity, the IRS conducts an initial investigation as part of an audit and may refer the case to the Department of Justice. Even when clear evidence of tax fraud has been obtained, the IRS revenue agent conducting the civil audit may continue to request information from the…
Better than a Soap Opera? Trust Fund Tax Disputes
One of the most important financial responsibilities for any business is the timely payment of taxes, including payroll taxes. Payroll taxes are the taxes that employers withhold from their employees’ paychecks and then submit to the government on their behalf. They also include the employer’s portion of the tax. While some businesses may be tempted…
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…
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…