This article, authored by Robert E. McKenzie, was originally published in CPA Magazine.
By Robert E. McKenzie 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…
106 Swiss banks have signed agreements to provide information about U.S. account holders. "The current Offshore Shore Disclosure Program (OVDP) began in January 2012 continues until it is terminated by the Service. Taxpayers whose names have yet to be disclosed…
On September 13th, Robert E. McKenzie participated in an IRS panel on the dissolution of business partnerships and marriages. Topics discussed: Introduction Hazards to preparer similar in business breakup and marriage breakup Circular 230 provision Divorce Change in filing status When…
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.
How Foreign Investors Can Get A Green Card In Exchange For $1 Million
Robert E. McKenzie quoted in Accounting Today on Newt Gingrich tax avoidance
On January 9, 2012 the Internal Revenue Service reopened the offshore voluntary disclosure program to help people hiding offshore accounts get current with their taxes and announced the collection of more than $4.4 billion so far from the two previous international programs.
On January 6, 2012 he Internal Revenue Service released a new set of tax gap estimates for tax year 2006. The tax gap is defined as the amount of tax liability faced by taxpayers that is not paid on time.
For bankruptcy cases filed after October 16, 2005, the Bankruptcy Code requires Chapter 13 debtors to file all required tax returns for tax periods ending within 4 years of the debtor’s bankruptcy filing. All such federal tax returns must be filed with the IRS before the date first set for the first meeting of creditors. The debtor may request the trustee to hold the meeting open for an additional 120 days to enable the debtor to file the returns (or until the day the returns are due under an automatic IRS extension, if later). After notice and hearing, the bankruptcy court may extend the period for another 30 days. Failure to timely file the returns can prevent confirmation of a Chapter 13 plan and result in either dismissal of the Chapter 13 case or conversion of the case to a Chapter 7 case.