Eli S. Noff, Esq.,CPA, PartnerBrent Conrad For tax purposes, a non-U.S. citizen is either a nonresident alien or a resident alien. All aliens are considered nonresident aliens, unless they pass the green card test or the substantial presence test. A person meeting either of these tests is considered a resident alien. Since aliens are taxed […]

Glen E. Frost, Esq., CPA, Managing Partner For many years, the persistent call for change in the taxation of American corporations and individuals abroad has gone unanswered. However, the current administration’s actions, suggest the very real possibility of new tax rules, sooner rather than later. Indeed, assuming no major legislative disturbance or some catastrophe, such […]

Eli S. Noff, Esq. Partner The recent Tax Court’s Alterman v. Commissioner [1] decision is a lesson in Accounting 101 for Cannabisseurs. Well, technically it’s a valuable lesson about record-keeping to all taxpayers who are subject to Internal Revenue Code (I.R.C.) §280E — but with the currently high audit rates for the marijuana industry, it’s […]

On April 5, 2018, the Chief Counsel’s Office provided advice in Notice CC-2018-005 to Chief Counsel attorneys who handle I.R.C. §7345 passport actions. The Chief Counsel’s Office detailed both the certification and reversal processes for “seriously delinquent taxpayers,” as well as the procedures for the judicial review of certifications. Lastly, the Notice indicates that since […]

Rebecca Sheppard, Esq. Have you ever considered filing an offer in compromise with the IRS to “settle your debt for pennies on the dollar”? Until recently, filing an offer in compromise was believed to create an automatic hold on collection action–i.e., the IRS would not be able to levy your property once it was filed. […]

Eli S. Noff, Esq. CPA, Partner Wesley Snipes and the IRS have been at odds for many years. From 1999 to 2001, Snipes simply didn’t file returns and failed to pay millions of dollars in taxes. For his part, Snipes has denied being a tax protestor; rather, he claims to have relied on professional advice […]

Eli Noff, Esq.,CPA, Partner The taxpayer in Berkun v. Commissioner1 ultimately raised two collection due process arguments too late for consideration on appeal, but the Eleventh Circuit apparently found them worthy enough to highlight in a published opinion. Although the Eleventh Circuit uses a popular Seinfeld reference to describe its own non-substantive ruling in Berkun […]

Glen Frost, Managing Partner The Comptroller’s Field Enforcement Division and the Criminal Investigations Division of the Maryland Attorney General’s Office, working in tandem, investigated and prosecuted two more Maryland tax preparers—resulting in guilty pleas. On July 24, 2018, Maryland Attorney General Brian E. Frosh and Comptroller Peter Franchot announced that two tax preparers operating in […]

Maryland residents who owe federal income tax that they cannot pay at one time should learn about the IRS installment agreement. Many taxpayers struggle when the amount of federal income tax they owe is more than what they are able to pay. This can understandably be a stressful experience. However, an Internal Revenue Service installment […]

In Borenstein v. Commissioner, 149 T.C. No. 10 (Aug. 30, 2017), for the first time, the Tax Court has interpreted the final sentence of IRC §6512(b)(3) as applied to the fact pattern in this case. The Tax Court’s interpretation resulted in the taxpayer losing a significant refund for tax overpayments, because the IRS notice of […]