The IRS Requires Six Years of Filed Income Tax Returns for the Taxpayer to be in Compliance with Tax Filing Requirements

January 29, 2021 Filed under

Some taxpayers have not filed tax returns for many years. When I am contacted by these taxpayers who now wish to comply with tax laws, I am asked how far back the taxpayer needs to go to file past due, unfiled tax returns. Often times, the longer the taxpayer must go back to prepare tax…

The IRS May Assert New Deficiencies and New Legal Theories in Tax Court

January 27, 2021 Filed under

At the conclusion of an audit where the IRS determines that additional tax is due and owing, the IRS provides the taxpayer with a Notice of Deficiency,[1] also known as a 90-day letter, wherein the IRS sets forth the additional amount of tax and forth the grounds for which the IRS has determined that additional…

Montana Property Taxpayers Must Have Good Evidence of Market Value and a Knowledge of Law to Succeed on a Property Tax Appeal – Part 1 of 2

January 4, 2021 Filed under

Many Montana property tax appeals are lost by the taxpayer due the taxpayer’s failure to present good evidence and to understand basic principles of property and property taxation. Such was the case of the taxpayer in a recent decision of the Montana Tax Appeal Board in Virgina Apts. LLLP v. Montana Department of Revenue.[1] In…