Western States Tax Advisor

Crowley Fleck PLLP is pleased to announce that the IRS Independent Office of Appeals has ruled completely in the favor of taxpayers represented by Crowley Fleck tax attorneys Jared M. Le Fevre and Lucas Forcella. The taxpayers had received an audit adjustment from the IRS when a Form 1099 was not included as taxable income […]

I handled a recent offer in 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 employment, which brought a change to […]

This is a continuation of a brief overview of key Wyoming property tax principals for Wyoming ad valorem taxation. Board of Equalization. The County Commissioners sit as the Board of Equalization.[1] The Board of Equalization hears complaints of property assessments.[2] Presumption. Once an assessor arrives at a value for a property, “[a] strong presumption favors […]

Wyoming does not have a state income tax. Therefore, property taxation, also known as ad valorem taxation, plays a key role in funding Wyoming state and local government operations. Below is a brief overview of key Wyoming property tax principles for Wyoming ad valorem taxation. Constitution. The Wyoming state Constitution is the starting point for […]

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 tax collections, which may be […]

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. The taxpayer often instead considers […]

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 Appeals. In a Collection Due […]

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 that the spouse qualifies for […]

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 joint tax debt, and the […]

In the past year, the Director of the Montana Department of Revenue (“DOR”), Brendan Beatty, spoke to the Taxation Committee of the Montana State Bar Association, of which I am the Chairman. Director Beatty was appointed Montana DOR Director by Governor Greg Gianforte in 2021. Director Beatty previously served for over 20 years as legal […]