eric l green: Innocent Spouse Treatment by the IRS in Greenwich, CT
- 12/15/13 10:44 AM
The focus of our practice is civil and criminal taxpayer representation, and see many taxpayers who find out about a tax debt that truly belongs to their spouse (or former spouse) in Greenwich, Connecticut. There are a few basics you need to understand about IRS federal tax liabilities and innocent spouse claims.
Most taxpayers realize that there are tax savings when filing a joint tax return with their spouse. However, in signing a joint return with their spouse they are accepting responsibility for any liability that flows from that return, both on the return and any additional assessment made later, … (0 comments)
eric l green: Why Compromising your IRS Tax Debt in Stamford, CT May Be Easier Than You thought!
- 11/27/13 10:18 PM
The focus of our practice is civil and criminal taxpayer representation and bankruptcy, and see many taxpayers in Stamford, Connecticut struggling with back tax debt. In addition, as someone who trains other tax practitioners to handle IRS collection issues, I am shocked at the low rate of acceptance for filed IRS Offers in Compromise. The reality is that if you understand the rules taxpayers should know if their offer-in-compromise will be accepted before they ever ship their forms into the IRS. An IRS Offer-in-Compromise is a formula called “Reasonable Collection Potential.” That formula consists of net equity in assets and future … (1 comments)
eric l green: IRS Rep Course: The CCH IRS Representation Course is Now Available
- 07/19/13 10:27 PM
The focus of our practice is civil and criminal taxpayer representation, and as many of you have known, we have been working very hard with CCH to develop an online IRS representation training program to train attorneys, certified public accountants (“CPAs”) and enrolled agents (“EAs”) in how to handle routine IRS representation matters. The program is now available.The brochure for the program is found by clicking here:http://www.cchgroup.com/opencms/opencms/web/TAA/LP/all/IRS-Cert/IRS_Rep_Program.pdf The site for the product is here: http://www.cchgroup.com/webapp/wcs/stores/servlet/content_LP_irs-cert The product is designed to take practitioners who know absolutely NOTHING about the IRS and teach them the basics so they can begin handling routine matters.The … (2 comments)
eric l green: Estate Refunds for Same Sex Marriages in Stamford, CT as DOMA struck Down by Supreme Court
- 06/26/13 12:46 AM
The focus of our practice in Stamford and New Haven Connecticut is estate planning, as well as civil and criminal taxpayer representation. With the United States Supreme Court’s decision to strike down the core of the Defense of Marriage Act (“DOMA”), suddenly same sex couple in Stamford, Connecticut and elsewhere who have been denied the federal estate exemption may now seek a refund from the IRS for all those estate taxes and income taxes paid that would otherwise have been exempt. Currently, the federal estate tax exemption is $5.25 million, however, married couples are entitled to an unlimited marital estate tax … (0 comments)
eric l green: Stamford, Connecticut or Elsewhere, Meet the new IRS SEP Examiner
- 06/08/13 07:22 AM
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)
eric l green: 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)
eric l green: 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)
eric l green: 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)
eric l green: 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 … (0 comments)
eric l green: 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)
eric l green: 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)
eric l green: 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)
eric l green: 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)
eric l green: 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)
eric l green: 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)
eric l green: 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)
eric l green: 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)
eric l green: 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)
eric l green: Eric Green to Speak on Resolving Your Client's Payroll Tax Nightware!
- 09/22/12 12:02 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)
The IRS makes its proposed adjustment to the return final and issues a 90 Day Notice of Deficiency, and The return created for the taxpayer in … (0 comments)
News, updates and innovative discussion of what is happening in the world of estate planning, tax planning, and criminal and civil taxpayer representation.
The focus of our practice is civil and criminal taxpayer representation, and see many taxpayers who find out about a tax debt that truly belongs to their spouse (or former spouse) in Greenwich, Connecticut. There are a few basics you need to understand about IRS federal tax liabilities and innocent spouse claims.
;)
;)
;)
