A revenue procedure recently issued by the Internal Revenue Service may offer a settlement advantage to small business owners who find themselves embroiled in a tax controversy.Specifically, Revenue Procedure 2017-25 sets up an administrative option called the Small...
Tax Controversies
Should you switch business forms to utilize tax savings?
In order to provide the best advocacy for our clients, our Connecticut tax law firm closely follows proposed changes in state and federal tax law. A recent federal proposal may impact a company’s choice of business structure.Several factors inform the choice of a...
Does the IRS pay closer attention to partnerships?
A majority of workers have federal, state and FICA taxes withheld from their paychecks. The withholding consists of the employee’s contributions and the employer’s matching share. For those who are self-employed or receive payments via a Form 1099, however, there are...
The latest craze: IRS Fast Track Mediation
Mediation is becoming a buzzword in more than just civil and divorce litigation. The IRS has also joined in this trend with its IRS Revenue Procedure 2016-57, titled Fast Track Mediation-Collection.Under the new procedure, an IRS Office of Appeals mediator is assigned...
How does the IRS evaluate whether deductions are reasonable?
A new ruling by the U.S. Tax Court might be of particular interest to small business owners.The dispute between the IRS and the business at issue arose over the amount of deductions the company claimed on its tax return for the wages of its two highest-ranking...
Will the IRS impute LLC members with self-employment tax?
In last week’s post, we talked about new tax rules that may increase the risk of audits to general partnerships. Yet the tax obligations of LLC members may also be confusing. According to one commentator, many LLC members are still confused about whether provisions of...
Negotiating an IRS settlement might become more difficult
One of the advantages of consulting with an attorney regarding an IRS tax controversy or dispute is the settlement angle. An attorney's training in negotiating may prove useful in estimating the litigation hazards and providing a ballpark settlement figure that would...
City settles IRS tax dispute to save its credit rating
Even a municipality can get into trouble with the Internal Revenue Service. In a recent example, the city of Scottsdale agreed to a $750,000 settlement to resolve a tax dispute.The tax relates to the city’s bond holdings. The city used a portion of its proceeds from...
Talk to an attorney before filing an amended tax return
A taxpayer that amends a tax return may be attempting to do the right thing. Yet before taking this action, an individual might benefit from a consultation with a tax attorney.Notably, there may be reasons not to amend a return. Signing a return is akin to filing it...
Decision in federal tax refund lawsuit may prompt IRS reforms
Tax controversies that go to trial may result in favorable precedents, possibly even impacting IRS procedures. In a recent example, commentators question whether a federal tax refund lawsuit brought by Wells Fargo & Co. may spur other refund claim filings and/or...