Avoiding Offshore Penalties by Voluntary Disclosure

Robert E. McKenzie Audio Discussion: Avoiding Offshore Penalties by Voluntary Disclosure

2014 IRS Representation Update

 

2014 IRS REPRESENTATION UPDATE ©2014

By: Robert E. McKenzie

1.  A CHANGING IRS

 

IRS Workforce

1.10    Because of Congressional cuts in IRS budgets its workforce continued to shrink until 2008. In 2009 and 2010 the IRS had its budgets grow and its workforce grew. In 2011 the IRS budget was frozen and its workforce shrank. In [...]

7 Million Taxpayers Fail To File Their Income Taxes

7 Million Taxpayers Fail To File Their Income Taxes

Nominee Liens And Alter Ego Liens

Nominee Liens & Alter Ego Liens

By Robert E. McKenzie ©2012

 

 

Depriving Taxpayers of Administrative
Due Process of Law

Many
practitioners have observed the aggressive approach that the IRS has recently
taken to collect taxes from alleged nominees and alter egos of delinquent
taxpayers. This summary collection approach deprives the alleged nominees of
administrative due process of law. In most [...]

Swiss Bank Secrecy Succumbs To U.S. Tax Enforcers

Swiss Bank Secrecy Succumbs To U.S. Tax Enforcers

 

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Robert E. McKenzie’s 2014 Speaking Engagements

 

2014

 

January 22, 2014

Teleseminar

Winning Strategies LLC

 

January 28, 2014

Teleseminar

U. S. Tax Agent Program

 

May 1, 2014

Chicago, IL

Chicago-Kent
College of Law

 

May 13-14, 2014

Las Vegas, NV

California
Society of Enrolled Agents

 

May 22-23, 2014

Wrightsville Beach, NC

North Carolina Society of
Enrolled Agents

 

May 29-30, 2014

Reno, NV

California
Society of Enrolled Agents

 

June 5, 2014

Park City, Utah

Utah
Society of Enrolled Agents

 

June 23-24, 2014

Fridley, MN

Minnesota
Society of Enrolled Agents

 

August 3-5, 2014

Las Vegas, NV

National
Tax Practice [...]

Robert McKenzie Forbes Blog on Reducing IRS Penalties

Robert McKenzie Forbes Blog on Reducing IRS Penalties

 

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Robert E. McKenzie Quoted in Forbes on Secret Israeli Bank Accounts

9-19-13 Robert E. McKenzie Quoted in Forbes on Secret Israeli Bank Accounts

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Reducing IRS Penalties

Procedural Requirements for Imposition of Penalties and Additions to Tax
The Internal Revenue Service Restructuring Act required that each notice imposing a penalty include the name of the penalty, the Code section imposing the penalty, and a computation of the penalty. The Act also requires the specific approval of IRS management to assess all non computer generated penalties unless excepted. This provision does not apply to failure to file penalties, failure to pay penalties, or to penalties for failure to pay estimated tax. [...]

5-27-12 Forbes Blog: New IRS Offer In Compromise Policies

Over the years the IRS offer in compromise program has been the subject of a great deal of criticism by Congress, the National Taxpayer Advocate and taxpayer representatives. The new initiative represents the most dramatic liberalization of IRS settlement policies ever announced. It represents a welcome change from an agency which has always placed substantial roadblocks to those seeking to compromise their tax [...]