stamford ct: Stamford, Connecticut or Elsewhere, Meet the new IRS SEP Examiner - 06/08/13 02:22 PM
The focus of our practice is civil and criminal taxpayer representation, and whether in Stamford, Connecticut or elsewhere, the IRS has stepped up its focus on identifying and prosecution criminal tax matters.  What has developed is a new Special Enforcement Program (“SEP”), and its examiners may be coming to taxpayer near you.
What is “SEP”? 
SEP is a specialized compliance program within the IRS Small Business/Self-Employed Operating Division directed toward that segment of the population which derives substantial income from either legal or illegal activities and intentionally understate their income. 
When we represent taxpayers before the IRS or the Department of … (0 comments)

stamford ct: Dealing with an IRS 8300 Exam in Stamford, Connecticut - 06/08/13 02:03 PM
The focus of our practice is civil and criminal taxpayer representation, and whether in Stamford, Connecticut or elsewhere, the IRS is the best agency for collecting and handling financial information, and has therefore increased its focus on 8300 Exams in Stamford, Connecticut and elsewhere. 
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 § 6050I requires the filing of a form to report cash receipts in excess of $10,000 by any business.  It also makes it a violation for taxpayers … (0 comments)

stamford ct: The IRS & Bank Secrecy Act enforcement in Stamford, Connecticut - 06/08/13 12:38 PM
The focus of our practice is civil and criminal taxpayer representation, and whether in Stamford, Connecticut or elsewhere, the IRS has increased its focus on Bank Secrecy Act issues, and in particular has created three new types of agent:
The Abusive Tax Avoidance Transaction (“ATAT”) Agent – IRM 4.32 The Bank Secrecy Act (“BSA”) Examiner – IRM 4.26.6 The Special Enforcement Program (“SEP”) Agent – IRM 4.16.1.3 When we represent taxpayers before the IRS or the Department of Justice Tax Division, we are usually focused on income, expenses and tax loss.  Not so with these new agents.  The focus here has … (0 comments)

stamford ct: 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)

stamford ct: 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)

stamford ct: IRS Tax Debt Stamford, Connecticut: IRS Offers New Penalty Relief and Expanded Installment Agreements to Taxpayers under Expanded Fresh Start Initiative - 03/12/12 05:46 PM
We frequently represent taxpayers involved with IRS tax issues in Stamford, Connecticut and elsewhere.  The Internal Revenue Service (“IRS”) announced a major expansion of its “Fresh Start” initiative to help struggling taxpayers by taking steps to provide new penalty relief to the unemployed and making Installment Agreements available to more people.
The changes include:
Certain taxpayers who have been unemployed for 30 days or longer will be able to avoid failure-to-pay penalties.  A six-month grace period on failure-to-pay penalties will be made available to certain wage earners and self-employed individuals. The request for an extension of time to pay will result … (2 comments)

stamford ct: IRS Audits in Stamford, CT: Taxpayers should be aware the IRS is no longer just seeking their receipts in civil and criminal tax exams, but their metadata as well! - 01/17/12 06:00 AM
We handle a significant number of civil examinations as well as represent taxpayers in criminal investigations by the IRS.  Recently the IRS Office of Chief Counsel issued new guidance on an IRS Examiner’s ability to summons a taxpayer to turnover electronic files containing metadata in the course of an IRS audit.
Taxpayers should be aware that the IRS seems to be expanding the range of electronic records requested during the course of an examination. The latest guidance sets forth the IRS’ position that examiners may summon metadata and a field directive issued in September instructs examiners to request accounting software backup … (1 comments)

stamford ct: CT DRS Criminal Prosecutions in Stamford, CT: Connecticut Department of Revenue Services (“DRS”) continues its criminal tax enforcement in Stamford, CT and elsewhere. - 01/14/12 08:02 AM
We frequently represent taxpayers in criminal tax cases with the Connecticut Department of Revenue Services (“DRS”) throughout Connecticut, including Stamford, Connecticut.   We can assure you that the DRS has increased its focus on enforcement and prosecuting businesses for the willful failure to file sales tax returns or the filing of false sales tax returns, as well as Larceny and filing of false income tax returns. 
In the last quarter of 2011 the CT DRS has confirmed its Tax Enforcement Agents made 53 arrests, many of which were for cigarette infractions and failing to operate without a sales tax permit.  The DRS … (0 comments)

stamford ct: 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)

stamford ct: 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)

stamford ct: Stamford CT IRS Criminal Tax Sentencing: Court Upholds Below-Guidelines Sentence for Tax Evasion - 12/07/11 10:18 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. Renner, 648 F.3d 680 (8th Cir. 2011), the Eighth Circuit upheld the district court’s decision to grant a downward variance in a tax evasion case based on the fact that the defendant had consulted with tax professionals, even though the jury did not believe the defendant met all the requirements for a good-faith defense.
We have seen the United States Supreme Court conclude recently that the federal sentencing guidelines are … (0 comments)

stamford ct: Stamford CT IRS Criminal Tax: Court Holds Unclaimed Deductions May Be Considered in Calculating Tax Loss - 12/07/11 10:00 PM
We represent taxpayers in IRS Criminal tax investigations frequently in Stamford, Connecticut as well as elsewhere in New England. In the recent decision reached in United States v. Hoskins, 654 F.3d 1086 (10th Cir. 2011), the Tenth Circuit held, inter alia, that a sentencing court was not precluded in appropriate cases from considering unclaimed deductions in determining tax loss under § 2T1.1 of the Sentencing Guidelines. In the present case, however, the lower court had not erred in rejecting the defendant’s calculation of tax loss based on previously unclaimed deductions.
Jodi Hoskins (“Hoskins”) and her husband operated an escort service in Salt Lake City, … (0 comments)

stamford ct: 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)

stamford ct: 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)

stamford ct: Stamford, CT IRS Foreign Bank Accounts: It’s Reported that the Swiss are Ready to Pay Billions and Disclose all United States Taxpayer Names to the IRS - 10/29/11 07:27 AM
We frequently represent taxpayers before the Internal Revenue Service (“IRS”) in all types of civil and criminal tax controversies, including foreign bank account issues.  It is now being widely reported that the Swiss banks will probably settle a sweeping U.S. probe of offshore tax evasion by paying billions of dollars and handing over names of thousands of Americans who have secret accounts, according to two people familiar with the matter.
 
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)

stamford ct: Stamford, CT IRS Gift Tax Returns: The Internal Revenue Service is Now Using State Property Records To Identify taxpayers Who Fail to File a Gift Tax return in Stamford, Connecticut and Elsewhere - 10/29/11 06:46 AM
We frequently represent taxpayers before the Internal Revenue Service (“IRS”) in all types of civil and criminal tax controversies. It is now being widely reported that the IRS has instituted a new gift tax compliance initiative, which is designed to respond to its suspicions of widespread failure to file gift tax returns. According to the IRS Federal/State Coordinator for Estate & Gift Taxes, Josephine Bonaffini, between sixty percent and ninety percent of taxpayers fail to file a gift tax return despite having engaged in a transaction requiring a return. According to Bonaffini, in the past two years, 323 taxpayers have been … (0 comments)

stamford ct: Stamford, CT DRS Contractors: The DRS Releases Special Notice 2011(17) Explaining the Amendments Affecting the Requirement for Nonresident Contractors to Provide Bonds. - 10/29/11 06:11 AM
We represent taxpayers before the Connecticut Department of Revenue Service (“DRS”) frequently.  A hot button issue for the last few years has been the issue of nonresident contractors and the requirement to provide a bond. The law requiring nonresident construction contractors to furnish security for Connecticut taxes arising from jobs performed in Connecticut has been changed in the following major ways:
·      Under the law as amended, there are two classes of nonresident contractors: verified and unverified. A nonresident prime or general contractor may gain verified status and thus eliminate the requirement to file a surety bond with the Department of … (0 comments)

stamford ct: CCH Presentation on Advanced Criminal Tax Issues - 10/28/11 03:31 PM
On Wednesday November 9th I will be presenting on a national Webinar for CCH, A Wolters Kluwer Company "Advanced Criminal Tax Issues: Protect Your Clients and Yourself"
You can get more information and register for this program at the link below:
http://online.krm.com/iebms/reg/reg_p1_form.aspx?oc=10&ct=0010300&eventid=18543
 
Make sure you understand the IRS criminal investigation process to avoid creating problems for your clients and your practice.When IRS criminal investigators begin looking at a taxpayer, the stakes change. As an advisor, your own freedom can be put at risk in such situations. It's not a time to learn as you go. In this two-hour CPE webinar … (0 comments)

stamford ct: IRS Tax Lien Subordination in Stamford, Connecticut: Having the IRS agree to subordinate its lien for a new creditor may not be as taxing as you thought! - 10/26/11 10:50 PM
We frequently represent clients who have a federal tax lien for outstanding IRS federal tax debt and can now obtain financing from a new creditor who insists the IRS subordinate its lien to their lien.
The IRS often agrees to a subordination, which means that it will agree, in writing, to allow another creditor to lend money to the taxpayer and have that lenders lien take priority over the existing IRS tax lien.  Inn order to obtain a subordination, we make a written request with very specific information that demonstrates how the IRS’s ability to collect the old tax debt will … (0 comments)

stamford ct: 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)

 
Eric L. Green Your IRS Tax Litigator (Convicer, Percy & Green, LLP) Rainmaker_large

Eric L. Green Your IRS Tax Litigator

Stamford, CT

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Convicer, Percy & Green, LLP

Address: New Haven, CT, Stamford, CT, Stamford, CT, 06033

Office Phone: (860) 657-9040

Cell Phone: (860) 494-4786

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