convicer percy green llp: Attorney Eric Green to Speak at the 2013 NATP Annual Meeting - 07/05/13 10:08 AM
Attorney Eric Green will be speaking at the NATP Annual Meeting July 10th and 11th in Phoenix Arizona.  He will be speaking on "Dealing with the IRS Collection Division" and "Handling IRS Examinations EWhen There Are Indications of Fraud."
Registration for the conference can be found at Registration.
Eric L. Green, Esq.
Convicer, Percy & Green, LLP
701 Hebron Avenue
Glastonbury, CT 06033
Ph. (860) 494-4786
Fax (203) 286-1311
egreen@convicerpercy.com 
www.convicerpercy.com 
 
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convicer percy green llp: Dealing with an IRS 8300 Exam in Stamford, Connecticut - 06/08/13 07:03 AM
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)

convicer percy green llp: The IRS & Bank Secrecy Act enforcement in Stamford, Connecticut - 06/08/13 05:38 AM
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)

convicer percy green llp: Criminal Tax in Stamford CT: An Introduction to the crime of Tax Evasion and defending taxpayers charged with it in Stamford, Connecticut - 06/02/13 12:40 PM
We frequently represent taxpayers and accountants in criminal tax matters, and whether in Stamford, Connecticut or elsewhere, the Department of Justice and IRS have both historically regarded Tax Evasion as the most important criminal tax statute.  It is also the criminal tax statute with the greatest impact for deterrence.
Under IRC § 7201, Tax Evasion has three elements:
1. Willfulness
2. The existence of a tax deficiency
3. An affirmative act constituting evasion or an attempted evasion of tax
The definition of willfulness is the “violation of a known legal duty.”  The willfulness test is a subjective one, and what I … (0 comments)

convicer percy green llp: Eric Green to Speak on Innocent Spouse and Divorce Tax Issues for CCH - 05/31/13 03:52 AM
I will be speaking on Divorce Tax Issues, Innocent Spouse and Injured Spouse for CCH via webinar on June 7, 2013.
Register Here!
I look forward to seeing you on the program!
Eric
Eric L. Green, Esq.
Convicer, Percy & Green, LLP
60 Long Ridge Road
Suite 202
Stamford, CT 06902
Ph. (203) 602-5550
Fax (203) 286-1311
Egreen@convicerpercy.com
www.convicerpercy.com
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convicer percy green llp: Attorney Eric Green to Speak on COD & Bankruptcy Tax Issues - 02/26/13 11:51 PM
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)

convicer percy green llp: Challenging IRS Tax Liabilities in New Haven, CT – It Ain’t Over ‘til It’s Over! - 02/23/13 09:58 PM
The focus of our practice is civil and criminal taxpayer representation, as well as bankruptcy and commercial litigation.  We frequently have New Haven taxpayers come to our office with a federal tax debt they do not believe they owe to the IRS.  
We can tell you that there are many opportunities to challenge a federal tax liability with the IRS, even after the opportunity to appeal has come and gone. 
Opportunities for challenging a tax liability include:
Filing a timely appeal with the IRS within 30 days after the proposed assessment; Filing a protest with the United States Tax Court within … (0 comments)

convicer percy green llp: IRS Summons Enforcement Stamford, CT: What happens if I don’t show up for an IRS Summons? - 01/23/13 12:43 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)

convicer percy green llp: IRS Summons Stamford, CT: The IRS’s ability to use its Summons power to obtain taxpayer information in Stamford, Connecticut. - 01/23/13 12:41 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)

convicer percy green llp: IRS Offer-in-Compromise in New Haven, CT: Why now may be the best time in memory to file an Offer-in-Compromise in Connecticut and clear up your old tax debt! - 12/30/12 01:54 AM
The focus of our practice is civil and criminal taxpayer representation, as well as bankruptcy and commercial litigation.  The IRS’s new 2012 “Fresh Start” initiative has made this time maybe the best time ever if you live in New Haven, Connecticut to file an Offer-in-Compromise (“OIC”) with the IRS.
We can tell you that in the past it has often been difficult to have an OIC accepted by the IRS.  However, in an effort to both help taxpayers and get its arms around its ever growing inventory of collection cases, the IRS has rolled out a 2012 initiative that makes it … (0 comments)

convicer percy green llp: IRS Tax Lien release in New Haven, CT: Recent IRS Policy Changes Has Made It Easier to Obtain a Tax Lien Release in New Haven, Connecticut! - 12/30/12 01:51 AM
The focus of our practice is civil and criminal taxpayer representation, as well as bankruptcy and commercial litigation.The IRS’s new 2012 “Fresh Start” initiative has made significant changes to the IRS Notice of Federal Tax Lien policy.
We can tell you that in the past it has often been difficult to have the IRS withdraw a Notice of Federal Tax Lien without actually disposing of the asset in question.Meanwhile the lien has caused unbelievable difficulties for the taxpayers, including ruining his or her credit and making it almost impossible to obtain any form of financing.
However, in an effort to both … (1 comments)

convicer percy green llp: Bankruptcy & Taxes in New Haven, CT: When is Bankruptcy the Best Option for Dealing with Back Taxes in Connecticut? - 12/22/12 09:07 AM
The focus of our practice is civil and criminal taxpayer representation, as well as bankruptcy and commercial litigation.  There is a common misconception that taxes are not dischargeable in bankruptcy.
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, including:
Discharging back income taxes; Forcing an installment agreement on an otherwise unwilling IRS or Connecticut DRS; Discharging other unsecured debts to free up … (0 comments)

convicer percy green llp: 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 06:38 AM
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)

convicer percy green llp: 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 11:42 AM
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)

convicer percy green llp: IRS Tax Debt and Bankruptcy in Stamford, Connecticut: Resolving your federal tax debt with the IRS through bankruptcy. - 07/07/12 09:43 PM
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)

convicer percy green llp: IRS Criminal Tax Prosecutions in Stamford, Connecticut: IRS Releases 2011 criminal Tax Enforcement data! - 03/27/12 01:02 PM
We frequently represent clients in federal IRS criminal tax investigations in Stamford, Connecticut.  In it worthy to note that the IRS released its 2011 statistical data today.
In 2011, the IRS Criminal Investigation Division initiated 4,720 criminal tax investigations.  Of those investigations initiated, 3,410 were referred for criminal prosecution.  These 4,720 cases included:
1,922 legal source crimes; 1,810 illegal source crimes; and 988 Narcotics-related financial crimes. When we handle these situations for taxpayers our focus is usually to try and have the criminal investigation killed and the case returned to the civil exam division.  The reason is that, the longer the … (1 comments)

convicer percy green llp: IRS Tax Debt Stamford, Connecticut: IRS Offers New Penalty Relief and Expanded Installment Agreements to Taxpayers under Expanded Fresh Start Initiative - 03/12/12 10:46 AM
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)

convicer percy green llp: IRS Tax Missing Returns Stamford, CT: Why you may not want to file those back taxes jointly in Stamford, Connecticut! - 03/01/12 05:21 AM
We frequently have taxpayers in Stamford, CT contact us for help because they have filed several years of missing tax returns (on the advice of their preparer) jointly, and now the IRS collection division is pursuing them and their spouse.
I will be the first to agree that, in most cases, filing a joint tax return with your spouse can save federal taxes.  There are some instances, however, in which you DO NOT WANT TO FILE A JOINT RETURN!
A real life example that came into our office was the following: husband was self-employed and wife was a stay-at-home mom.  … (0 comments)

convicer percy green llp: IRS Criminal Tax Stamford CT: What causes an IRS audit to be referred for criminal prosecution in Stamford, CT and elsewhere? - 02/25/12 10:29 AM
We frequently represent taxpayers before the IRS during routine audits in Stamford, Connecticut, as well as criminal tax investigations and eggshell audits (civil audits where tax fraud exists but the IRS has not found it yet).  I am often asked what causes an IRS examiner to send a case to the criminal investigation division (“CI”)?
The Internal Revenue Manual (“IRM”) states that an IRS tax auditor should refer the case for criminal investigation when there are “firm indications of fraud.”
Great: so what does that mean?
There are a number of items that may raise an examiner’s suspicion of tax fraud: … (2 comments)

convicer percy green llp: IRS Exam Accountant Privilege Stamford CT: Why, if there are fraud issues with your tax return, your accountant may be your worst enemy during an IRS audit in Stamford, CT! - 02/25/12 10:08 AM
We frequently represent taxpayers before the IRS during routine audits in Stamford, Connecticut, as do many CPAs or EAs.  Having your CPA or EA handle your audit may be a costly mistake if there are potential tax fraud issues involved with the return.
Accountants, defined as anyone allowed to practice before the IRS (CPAs and EAs) enjoy a privileged relationship with their clients in routine tax matters.  Internal Revenue Code (“IRC”) Section 7525 creates a confidential relationship for accountants similar to that of attorneys with their tax clients in civil tax matters.
Unlike the attorney-client privilege, the 7525 accountant-client privilege ceases … (2 comments)

 
Eric L. Green, Your IRS Tax Litigator (Tax Rep LLC)

Eric L. Green

Your IRS Tax Litigator

New Haven, CT

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Tax Rep LLC

Address: New Haven, CT, Stamford, CT, New York, NY, West Hartford, CT

Office: 203-285-8545

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