NOL Audits. An area ripe for audit by the IRS is net operating losses (“NOL”) carried forward from past years to the current tax year. In a significant amount of audits, the taxpayer may lack detailed evidence to substantiate the NOL. What is to be done in such a case? The Tax Court was recently…
Read MoreMany spouses file a Married Filing Jointly federal income tax return in order take advantage of tax rates, deductions and other tax items. But Married Filing Jointly also imposes joint and several liability for the tax on the husband and wife, meaning that either spouse is fully liable for the joint tax debt and the…
Read MoreTaxpayers owing outstanding federal income tax may wish to avoid the IRS’ filing of a Notice of Federal Tax Lien (“NFTL”). Some reasons for seeking avoidance of a NFTL are if there is an impending property sale, hit on credit, and general anxiousness about the public nature of tax liability coming to light. The IRS…
Read MoreTaxpayers who owe delinquent taxes to the IRS or have tax liens on their property receive many different tax notices from the IRS in an attempt to collect. However, taxpayers may also receive other official looking notices not from the IRS, but that appear to be tax notices. A copy of one such notice recently…
Read MoreThe IRS has announced that conferences with the IRS Office of Independent Appeals will now be offered by videoconference at the request of the taxpayer. See AP-08-0321-0009: Memorandum for Required Use of Virtual Conferences. IRS Appeals will use WebEx and ZoomGov platforms. Pursuant to the new IRS Appeals policy: [Taxpayers] may request an in-person conference…
Read MoreIn part 1 of this article, I discussed spending down assets for an offer in compromise and how the IRS may treat dissipated assets spent on items other than delinquent tax debt. Unless assets are spent on necessary items for health and welfare of the taxpayer and family or for the production of income, the…
Read MoreTaxpayers owing outstanding federal income tax liability have various options for dealing with the delinquent taxes, including installment payment agreements, offers in compromise and bankruptcy. One option that doesn’t require the taxpayer to pay any money out of the pocket is to be placed in currently not collectible status (“CNC”). What is CNC. CNC means…
Read MoreCrowley Fleck’s Employment Law Practice Group has released its latest Employment Law Quarterly Update - April 2021. Please contact one of our attorneys should you have any questions regarding this newsletter. Employment Law Quarterly Update Newsletter - April 2021
Read MoreTypically for an offer in compromise based on inability to pay the income tax owed, the IRS requires the taxpayer to pay over the equity of the taxpayer’s assets, including cash bank accounts and investment accounts, in order to settle the tax debt. There are exceptions to this general rule and taxpayers are urged to…
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