Form 4340 is Sufficient Corroborating Evidence Proving Issuance of Notice of Deficiency

On behalf of Frost Law posted in on April 23, 2020.

Eli S. Noff, Esq. CPA, PartnerMary Lundstedt, Esq., Associate On January 28, 2018, the court in U.S. v. Meyer,1considered a challenge to the proper mailing of Notices of Deficiency for two tax years and found Form 4340 sufficient as corroborating evidence for both years. Background A deficiency assessment results from the Internal Revenue Service’s (IRS) […]

Tags: Articles, IRS


HoweyCoin—Too Good to be True

On behalf of Frost Law posted in on April 23, 2020.

ByMary Lundstedt, Esq. “If you’ve ever been tempted to buy into a hot investment opportunity linked with luxury travel, the Securities and Exchange Commission has a deal for you.” Sound too good to be true? It is. This announcement was made in the May 16, 2018 U.S. Securities and Exchange Commission (SEC) press release which […]

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Audit of the Offshore Voluntary Disclosure Program

On behalf of Frost Law posted in on April 23, 2020.

The Treasury Inspector General for Tax Administration (“TIGTA”) completed an audit of the Offshore Voluntary Disclosure Program (“OVDP”). US citizens are taxed on their worldwide income and must report bank accounts when their aggregate balance exceeds $10,000. The OVDP and other similar programs allow taxpayers a mechanism to come forward and get into compliance with […]

Tags: Articles, Audits, IRS


Celebrities’ Initial Coin Offering Endorsements Under SEC Scrutiny

On behalf of Frost Law posted in on April 23, 2020.

Mary Lundstedt, Esq. Cryptocurrency start-up firms sometimes attempt to raise funding for an original cryptocurrency venture through Initial Coin Offerings (ICOs). Typically, the firm presents a whitepaper plan detailing the: (1) project requiring funding, (2) amount of funding needed, (3) amount of cryptocurrency that investors will retain, (4) specific currency accepted, and (5) timeline for […]

Tags: Articles, Tax Crimes


Credit Suisse Hearings focus attention on Foreign Bank Accounts

On behalf of Frost Law posted in on April 23, 2020.

The chief executive of Credit Suisse recently appeared in front of a Senate subcommittee to answer questions related to the bank’s role in aiding tax evasion. A similar hearing in 2008 resulted in a $780 million fine for Swiss bank UBS after the bank admitted helping U.S. taxpayers shield assets to avoid taxes. In conjunction […]

Tags: Articles, IRS, Tax Topics


Qualified Terminable Interest Property (QTIP) Trust

On behalf of Frost Law posted in on April 23, 2020.

A QTIP trust, despite its silly name, is a valuable estate planning tool. QTIP, or “Qualified Terminable Interest Property” is a name derived from the tax law that legalises the tax benefits of the trust. When property is given to a spouse outright (not subject to a trust), it qualifies for what is known as […]

Tags: Estate Planning, Tax Topics, Articles


The Foreign Account Tax Compliance Act: What is FATCA?

On behalf of Frost Law posted in on April 23, 2020.

Eli S. Noff, Esq.,CPA, PartnerMary Lundstedt, Esq., Associate Brent Conrad In an effort to reduce persistent high unemployment rates resulting from the 2008 financial crisis, President Obama signed The Hiring Incentives to Restore Employment Act of 2010 (HIRE Act)1to incentivize employers to hire and retain workers. Tax incentives provided in the HIRE Act included: (1) […]

Tags: Articles, IRS, Tax Topics


Innocent Spouse Relief (IRC §6015)

On behalf of Frost Law posted in on April 23, 2020.

Eli S. Noff, Esq., CPA, PartnerMary F. Lundstedt, Esq., Associate Under Internal Revenue Code (IRC) §6013(d)(3), spouses who file joint income tax returns are subject to joint and several liability for the income tax reported on those returns. In other words, the IRS will hold each spouse responsible for the entire amount of tax due. […]

Tags: Articles, IRS, Tax Topics


Baltimore Police Commissioner De Sousa Charged With Tax Crime

On behalf of Frost Law posted in on April 23, 2020.

Mary Lundstedt, Esq. On May 10, 2018, the United States Attorney for the District of Maryland announced that new Baltimore Police Commissioner Daryl De Sousa has been charged with three misdemeanor counts of willful failure to file a U.S. individual income tax return. Specifically, the charges allege that Commissioner De Sousa failed to file returns […]

Tags: Articles, Tax Crimes


New Tax Laws in Maryland in Response to Federal Tax Reform

On behalf of Frost Law posted in on April 23, 2020.

Mary Lundstedt, Esq. On May 15, 2018, Maryland enacted laws which are projected to counteract the recent federal tax reform’s negative effects on a significant portion of Maryland taxpayers. Recent estimates issued by the Comptroller’s office indicated that 23% of Maryland taxpayers would experience an increase in their state and local taxes due to the […]

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