IRS

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 […]

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 […]

Eli S. Noff, Esq., Partner On March 13, 2018, the IRS issued news release, IR-2018-52, announcing that the Offshore Voluntary Disclosure Program (OVDP) will close on September 28, 2018. The OVDP’s objective has enabled willful US taxpayers with undisclosed foreign assets to become compliant with US tax laws, while simultaneously avoiding substantial statutory civil penalties […]

Glen E. Frost, Managing Partner The Internal Revenue Service (IRS) considers a passive activity as any activity involving the conduct of a trade or business in which the taxpayer does not materially participate.1Rental activity is considered a per se passive activity, regardless of the taxpayer’s participation level, unless the taxpayer can demonstrate that he or […]

From a tax perspective, an audit is one of the most challenging situations a taxpayer may confront. Whether you’re facing an audit now, or you’re simply concerned about the possibility of an audit, there are several things you need to know. Each year, the process of filing taxes fills many Americans with dread and frustration. […]

Eli Noff, Esq.,Partner As we reported last year, the IRS is actively targeting taxpayers with “seriously delinquent tax debt” for passport denial/revocation.[1]Recently, on July 12, 2019, the IRS released interim guidance for agency officials regarding passport decertification and revocation.[2]The guidance signifies a significant shift in enforcement. Until now, some certified taxpayers have experienced the enforcement […]

Eli Noff, Esq., Partner We’ve continued to report on the increasingly aggressive IRS posture towards uncovering tax evasion via cryptocurrency transactions.[1]Interestingly, we may now be seeing a trend in the courts indicating that the IRS will need to more carefully tailor summonses in cryptocurrency cases in order to survive the courts’ scrutiny of the allowed […]