The Taxation Committee of the State Bar of Montana BETTR (Business, Estates, Tax, Trusts, Real Estate) Section, for which I am Chair, had the opportunity to hear from Danielle Pennington, Collections Bureau Chief of the Montana Department of Revenue (“MDOR”) in February 2023. Ms. Pennington addressed many questions about MDOR […]
If Taxpayers Fail to Establish Evidence of a Loan, Bank Account Deposits May Be Taxable Income
During an IRS audit of a taxpayer that runs a business, it is not uncommon for the IRS to perform an analysis of a business’s bank deposits. If the taxpayer is not able to establish the source of the deposits, the IRS may consider the deposits to be taxable income. […]
Collection Due Process Hearing. A taxpayer is entitled to a Collection Due Process Hearing to determine if the IRS may correctly proceed with collection of tax or a notice of federal tax lien. The Collection Due Process Hearing is held before a settlement officer of the IRS Independent Office of […]
In Part I of this article, we discussed factors the IRS considers in determining whether innocent spouse relief under IRC § 6015(f) will protect one spouse from the other spouse’s failure to pay federal income tax. (https://crowleyfleck.com/what-to-do-when-your-spouse-doesnt-pay-the-tax-bill-part-1-of-2-2/) In Part 2, we will review the obligations of a taxpayer to prove […]
Many 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 […]