The IRS is permitted to file a Notice of Federal Tax Lien (“NFTL”) to perfect a tax lien that arises by operation of law under the Internal Revenue Code for unpaid federal tax. It may become necessary to obtain copies of the filed NFTL if the taxpayer, who is to have been mailed a copy,…
Read MoreConcluding the interesting remarks of a Montana IRS Criminal Investigations Agent addressing various tax crime issues to a group of civil tax lawyers: When a civil IRS auditor uncovers evidence of tax fraud during a tax audit, IRS Civil Exam can refer the case to IRS CI. However, having an IRS civil audit turn criminal…
Read MoreCrowley Fleck PLLP is pleased to announce that Brian Bjella, Ashley Burleson, Ben Cory, Peter Habein, Matt McLean, Steven Milch, and Lindsay Woznick have been recognized as Best Lawyers in America© 2022 Lawyers of the Year. This designation is given to a single lawyer in a specific practice area and location. Additionally, 46 of the…
Read MoreContinuing the interesting remarks of a Montana IRS Criminal Investigations Agent addressing various tax crime issues to a group of civil tax lawyers: Attorney advice to a taxpayer is a relevant defense for the taxpayer to raise to a tax crime. The IRS has summons or subpoena power to obtain bank records that go more…
Read MoreI recently moderated a presentation to a group of civil tax attorneys from an IRS Criminal Investigation (CI) Agent working in Montana. I requested that the CI Agent discuss what civil tax lawyers should know about tax crimes in Montana. Here are some interesting points raised in his remarks: 40-50% of IRS CI Agents are…
Read MoreI handled a recent compromise for a taxpayer based on doubt as to collectability. The offer was submitted pre-virus pandemic and was pending before the IRS for many months. During that time, the pandemic had changed the taxpayers finances in multiple ways. One of the taxpayers changed a job, which brought a change to income…
Read MoreAs discussed in the previous article, the first step for the taxpayer to challenge the property tax is to meet with the Montana Department of Revenue assessor for an informal review of the property. While over 90 percent of property tax disputes are resolved at informal review, the taxpayer retains the right to appeal. The…
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