irs exam: How to Bullet Proof Your Tax Return - 06/06/19 02:09 AM
So the IRS sent its letter and now the client is scrambling to find their documents and receipts that the dog didn’t eat!  Listen in this week and you can stop your client’s panicking.  On this week’s episode Eric and Damien Greathead of Receipt Bank discuss exactly how to make sure your tax return is bullet proof when Uncle Sam comes calling.  Receipt Bank is an amazing app, and Eric and Damien discuss the app, the IRS process and why and how Eric discovered the app and why he not only recommends it but has all of his attorneys at Green … (0 comments)

irs exam: New Haven CT & Estate Portability: Examine of Estate Returns Clarified - 03/10/18 03:34 AM
As part of our tax and estate planning practice in Connecticut and New York we do a lot of planning and estate administration.  Part of the estate documents we and many other planners put together include terminology regarding “Portability”.  In 2010, Congress introduced into the tax code with Internal Revenue Code ("IRC") 2010( c)(2) the concept of portability for certain estates.  Each estate has an applicable exclusion amount that it will not pay any estate tax. Federally in 2018 this amount is $11.2 million, and Connecticut is $2.6 million, but increasing over the next several years until it matches the federal … (1 comments)

irs exam: Podcast: What to do when the IRS Auditor is Batshit Crazy! - 09/04/17 03:33 AM
In this week's Tax Rep Podcast i deal with an issue that seesm to be coming up more and more: dealing with the auditor that either doesnt want to do his or her job, or worse, has decided to take out their frustrations on you and your client.  in "What to do when the auditor is batshit crazy" I discuss the things we are seeing from clients, and what you can do about it.  Documenting the case properly, responsing in a way that can be proven and tracked, and how to go nuclear back the IRS when it's called for.
Check out … (0 comments)

irs exam: 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)

irs exam: 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)

irs exam: 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)

irs exam: 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! - 01/16/12 10:00 PM
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)

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

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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News, updates and innovative discussion of what is happening in the world of estate planning, tax planning, and criminal and civil taxpayer representation.




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