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irs: Attorney Eric Green to Speak on COD & Bankruptcy Tax Issues - 02/27/13 07:51 AM
I will be speaking for CCH on a national webinar on March 6th on cancellation of Debt and Bankruptcy Tax Issues. The official program description is: Review the tax consequences of cancelled debts and consider the benefits of the Bankruptcy Code for resolving outstanding tax debts As the economy continues to stagger along, many taxpayers are being surprised at tax time when they receive a 1099-C for a debt they believed was simply written-off by the creditor. This two-hour online CPE seminar course will review the Cancellation of Indebtedness (COD) rules and review the IRC §108 exceptions. It will also discuss (0 comments)
irs: IRS Summons Enforcement Stamford, CT: What happens if I don’t show up for an IRS Summons? - 01/23/13 08:43 AM
The focus of our practice is civil and criminal taxpayer representation, and whether in Stamford, Connecticut or elsewhere, one of the most power tools the IRS has at its disposal to gather taxpayer information is its power to issue an administrative Summons. The IRS generally uses its administrative summons power to gather information – both written records and testimony – when it is seeking tax returns or conducting a tax investigation. When we represent taxpayers before the IRS or the Department of Justice Tax Division, we often get asked the question from our clients: “What if I don’t show up?” If (1 comments)
irs: IRS Summons Stamford, CT: The IRS’s ability to use its Summons power to obtain taxpayer information in Stamford, Connecticut. - 01/23/13 08:41 AM
The focus of our practice is civil and criminal taxpayer representation, and whether in Stamford, Connecticut or elsewhere, one of the most power tools the IRS has at its disposal to gather taxpayer information is its power to issue an administrative Summons. When we represent taxpayers before the IRS or the Department of Justice Tax Division, we often have to explain the administrative powers the IRS examiners or criminal investigators have. IRC § 7602 allows the IRS to examine records, issue a summons either for the records or the taxpayer themselves to appear, and take testimony. This is often done when (0 comments)
irs: Chapter 7 Bankruptcy & Taxes in New Haven, CT: When can a Chapter 7 Bankruptcy be used to Discharge Back IRS and CT DRS Taxes? - 12/22/12 02:38 PM
The focus of our practice is civil and criminal taxpayer representation, as well as bankruptcy and commercial litigation. We are frequently asked whether bankruptcy can be utilized to help taxpayers resolve their back taxes. We can tell you that there are many instances where bankruptcy may be the best option for resolving back federal and state taxes. There are a number of benefits for our Connecticut clients who seek to use bankruptcy as a means for resolving their outstanding tax issues. Each taxpayer’s situation must be analyzed, but there are a few basic rules for discharging a tax, including: The tax (0 comments)
irs: New Haven Connecticut Criminal Payroll Tax Prosecutions: The factors the IRS looks for in deciding to pursue a criminal employment tax case for unpaid payroll taxes. - 12/09/12 07:42 PM
Historically there have been few criminal employment tax prosecutions, however the IRS Criminal Investigation Division has suddenly focused on this area. The number of prosecutions for criminal employment tax violations under IRC § 7202 has swung up significantly in the last 2 years. We represent taxpayers in a number of criminal tax prosecutions, and can tell taxpayers that the things that the IRS Criminal Investigation Division looks for when deciding to pursue a criminal payroll tax case against a business owner. Those things they look for include: <!--[if !supportLists]-->• <!--[endif]-->Recidivism: Where the taxpayer has opened a series of companies that (0 comments)
irs: Eric Green to Speak on Resolving Your Client's Payroll Tax Nightware! - 09/22/12 07:02 PM
On October 4th I will lecture for CCH’s Webinar series on Resolving IRS Payroll Tax Issues, including the Trust Fund Recovery penalty under IRC Section 6672, third party liability under IRC Section 3505, resolving payroll tax issues and criminal payroll tax prosecutions under IRC Section 7202 and 7215. Tax practitioners can register at CCH. This talk will be part of a series for CCH throughout the Fall on civl and criminal tax issues. The scheduled talks are as follows: Thursday October 18, 2012 – Eggshell Audits: Handling IRS Civil examinations When There are Indications of Fraud Wednesday October 31, 2012 – The (0 comments)
irs: IRS Taxpayer Mistakes New Haven, Connecticut: Biggest Mistake #2 that Taxpayers Make when Dealing with the IRS in New Haven, CT: Not Appealing! - 09/02/12 06:13 AM
We frequently represent clients in IRS examination and Collection cases in New Haven, Connecticut, and can state that the Appeals function is one of the best ways to get your case resolved. One of the biggest mistakes we see taxpayers (and their tax practitioners) make is to not take advantage of the IRS Appeals function attached to both the IRS examination function and the IRS Collection Division. We understand dealing with the IRS can be intimidating, and the IRS examiners, in New Haven Connecticut and elsewhere, put pressure on taxpayers to not appeal their case. Trust me: Appeal! If you believe (1 comments)
irs: IRS Tax Debt and Bankruptcy in Stamford, Connecticut: Resolving your federal tax debt with the IRS through bankruptcy. - 07/08/12 04:43 AM
We frequently represent clients who owe significant sums of back taxes, to the IRS. Often, the question of bankruptcy is raised, and when it might be appropriate for use in resolving the federal tax issue with the IRS. We have seen a significant number of our clients resolve their outstanding IRS tax debts either completely, or reduce it significantly, through a Chapter 7 bankruptcy filing. In order for a tax to be dischargeable in bankruptcy, it must meet the following requirements: The tax must be at least 3 years old; The IRS cannot have filed a Substitute for Return (an (0 comments)
irs: IRS Innocent Spouse Relief in Stamford, Connecticut: IRS Releases New Proposed Guidelines To Allow More Taxpayers to Qualify for Innocent Spouse Relief - 01/05/12 09:39 PM
We handle many taxpayers seeking innocent spouse relief from the IRS. The Internal Revenue Service today released new proposed guidelines designed to provide relief to more innocent spouses requesting equitable relief from income tax liability. A Notice proposing a new revenue procedure, posted today on IRS.gov, revises the threshold requirements for requesting equitable relief and revises the factors used by the IRS in evaluating these requests. The factors have been revised to ensure that requests for innocent spouse relief are granted under section 6015(f) when the facts and circumstances warrant and that, when appropriate, requests are granted in the initial stage (1 comments)
irs: IRS Stamford CT: IRS Releases Guidance on Foreign Financial Asset Reporting - 12/15/11 03:56 PM
We frequently get involved in helping taxpayers sort out their foreign bank account issues with the IRS in Stamford, CT and elsewhere. The Internal Revenue Service in coming days will release a new information reporting form that taxpayers will use starting this coming tax filing season to report specified foreign financial assets for tax year 2011. Form 8938 (Statement of Specified Foreign Financial Assets) will be filed by taxpayers with specific types and amounts of foreign financial assets or foreign accounts. It is important for taxpayers to determine whether they are subject to this new requirement because the law imposes significant penalties (0 comments)
irs: Stamford CT IRS Criminal Tax: Venue for Failure to File FBAR Lies in Any District that Houses an IRS Office - 12/07/11 08:59 PM
We represent taxpayers in IRS Criminal tax investigations frequently, and often deal with foreign bank account issues in Stamford, Connecticut as well as elsewhere in New England. In United States v. Bradley, 644 F.3d 1213 (11th Cir. 2011), the Eleventh Circuit held, inter alia, that venue for failure to file an FBAR properly lies in any district that houses a local IRS office, so long as the chosen venue does not create a constitutional hardship for the defendant. As discussed above, the Bradleys and their company, Bio–Med Plus, Inc., engaged in multiple schemes to defraud the Florida and California Medicaid programs (0 comments)
irs: Stamford CT IRS Criminal Tax: Fifth Amendment Privilege Held to be Inapplicable to Subpoena for Foreign Bank Records Required under Bank Secrecy Act - 12/07/11 08:50 PM
We represent taxpayers in IRS Criminal tax investigations frequently, and often deal with foreign bank account issues in Stamford, Connecticut as well as elsewhere in New England. In In re Grand Jury Investigation M.H. v. United States, 648 F.3d 1067 (9thCir.2011), the Ninth Circuit held that foreign bank account records required to be kept under the Bank Secrecy Act (“BSA”) fall within the Required Records Doctrine, thus rendering the Fifth Amendment privilege against self-incrimination inapplicable to a subpoena for these records. When I am asked by clients about records demanded by the government, I often have to explain that records required (0 comments)
Bloomberg is reporting that U.S. and Swiss officials are concluding negotiations on a civil settlement amid U.S. criminal probes of 11 financial institutions suspected of helping American clients hide money (0 comments)
irs: IRS Offer-in-Compromise in Stamford, Connecticut: How does the IRS determine what to accept for an Offer-in-Compromise? - 10/26/11 10:47 PM
We frequently represent clients who want to resolve their outstanding IRS federal tax debt with an Offer-in-Compromise in Stamford, Connecticut often ask us how much they have to offer? The truth is it depends upon the individual’s personal financial situation. The IRS looks to obtain what it can based upon the taxpayer’s Reasonable Collection Potential, or “RCP.” It is the RCP that will determine whether the taxpayer’s Offer-in-Compromise is ultimately accepted by the IRS. So what is involved with the RCP? For our clients in Stamford, Connecticut and elsewhere, the RCP consists of what the IRS could expect to collect from (0 comments)
irs: IRS Criminal Payroll Tax prosecutions in Stamford, Connecticut: If you owe payroll taxes, beware: the IRS prosecution of employers is on the upswing. - 10/26/11 10:43 PM
We frequently represent clients who owe significant sums of back payroll taxes, to the IRS. For years it was rare to see a criminal prosecution for unpaid payroll taxes, but that is no longer the case. We have seen a significant increase in IRS criminal prosecutions, and it appears payroll taxes are a new IRS Criminal Division priority. Internal Revenue Code Section 7202 makes it a crime for an employer to willfully fail to account for and pay over payroll taxes. We always advise our clients in Stamford, Connecticut and elsewhere to take serious steps to resolving their outstanding payroll (0 comments)
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