new haven ct: New Haven, CT: What is Reasonable Compensation for an S Corp Owner? - 03/10/24 06:53 AM
I am a tax attorney in New Haven, Connecticut that help taxpayers dealing with IRS audits and back balances all over the country. For S Corporation owners having a grasp and making the right call on compensation is not just smart business practice—it's a vital part of following IRS rules. Reasonable compensation ensures that shareholder employees are fairly paid for their efforts while steering clear of tax complications. In this piece we'll delve into what reasonable compensation involves, its importance and how S Corporation owners can smoothly navigate IRS guidelines.
Reasonable compensation as defined by the IRS refers to the pay that … (1 comments)

new haven ct: New Haven, CT: The IRS Crackdown on Non-Filers: What You Need to Know - 03/09/24 05:20 AM
I represent taxpayers with tax issues in New Haven, Connecticut as well as all over the country before the IRS, Department of Justice Tax Division and State Departments of Revenue.  The IRS knows there are more than 10 million non-filers and has known who they are for several years now.  Last week the IRS announced the long awaited move against the top 125,000 high-income non-filers is starting. 
For those who haven't filed their taxes there are a few initial considerations:
How many years must they file? Should they just file or should they request Voluntary Disclosure? Compliance with tax regulations goes beyond … (0 comments)

new haven ct: How to Settle a Tax Debt, Part 3: Uncollectible Status - 03/02/24 03:33 AM
I am a tax attorney in New Haven, Connecticut that helps taxpayers struggling with tax debt all over the country.  Dealing with tax matters can feel overwhelming, for any taxpayer. Whether its dealing with mounting debts or the looming threat of IRS enforcement actions the financial strain can be quite daunting. Fortunately there are options to help individuals facing challenges one being the option to acquire Uncollectible Status, also known as Currently Not Collectible (CNC) status from the IRS.
Uncollectible status offers a relief for taxpayers experiencing hardship and unable to fulfill their tax obligations. When granted status the IRS puts a … (3 comments)

new haven ct: How to Settle a Tax Debt, Part 2: Installment Agreements - 02/29/24 03:20 AM
I am a tax attorney in New Haven, Connecticut that helps taxpayers struggling with tax debt all over the country.  Facing a tax debt can be a daunting experience, but the IRS offers options for taxpayers to manage their obligations through installment agreements. However, these agreements come with their own set of rules and considerations that taxpayers and practitioners must understand to navigate effectively.
An installment agreement is essentially a structured payment plan between the IRS and a taxpayer to settle back taxes over a period of time, typically in monthly installments. While it offers relief by spreading out the payments, there … (3 comments)

new haven ct: Criminal Tax New Haven CT: Former New Haven Tax Preparer is Sentenced - 01/15/20 06:41 AM
John H. Durham, United States Attorney for the District of Connecticut, announced that DEVON WILLIAMS, 30, of Atlanta, Georgia, was sentenced today by U.S. District Judge Janet C. Hall in New Haven to eight months of imprisonment, followed by one year of supervised release, for preparing false tax returns
According to court documents and statements made in court, Williams formerly owned and operated Perfect Preparers, LLC, a tax preparation business based in New Haven.  Between approximately 2014 and 2017, Williams prepared numerous federal tax returns for clients that contained inflated deductions, including false deductions for unreimbursed employee expenses, charitable donations, and mortgage … (0 comments)

new haven ct: IRS Announces the end of the Offshore Voluntary Disclosure Program - 03/14/18 05:51 AM
The focus of our practice is civil and criminal taxpayer representation, and so we wanted to make everyone aware that the IRS has announced it will begin to shut down the 2014 Offshore Voluntary Disclosure Program (OVDP). The program will close on September 28, 2018. Therefore, U.S. taxpayers with undisclosed foreign financial assets have a limited amount of time to use the OVDP before the program ends.
Background
More than 56,000 taxpayers have used one of the IRS disclosure programs since the ODDP initially launched in 2009. Those taxpayers have paid a total of $11.1 billion in back taxes, interest and penalties. … (0 comments)

new haven ct: Look Mom No Documents!: Resolving Your Tax Problem with 1 Phone Call - 10/09/17 05:29 AM
In this week's Tax Rep Podcast I discuss the IRS agreeing to extend its pilot program of the $100,000 Streamlined Installment Agreement ("SIA").
For those of you unfamiliar with the SIA, it is an installment agreement where the taxpayer agrees to repay the IRS overtime.  But unlike a regular agreement, an SIA allows the taxpayer to just agree to the repayment number with the IRS without providing any documentation: no Form 433, no documentation on assets and income, and no attorneys fees!
The SIA was capped so that those who owe $50,000 or less and could afford to pay it over 72 months … (0 comments)

new haven ct: New Haven CT: Court Dismisses Attempt to Invalidate IRS Tax Liens - 12/04/16 08:48 AM
The focus of our practice is on civil and criminal tax controiversies in Connecticut and New York City.  An individual’s petition to invalidate four Notices of Federal Tax Liens filed against him was dismissed for failure to state a claim on which relief could be granted. He petitioned the court to invalidate the liens based on a number of tax-protestor-type arguments including, inter alia, that there was no authority for filing the Notices against him under the Administrative Procedures Act, that no Executive Orders existed to establish internal revenue districts for the collection and enforcement of income taxes, the regulations used … (0 comments)

new haven ct: Payroll Tax Debts in New Haven CT: The IRS Disqualified Payroll Levy - 05/22/16 10:06 AM
It is not infrequent that companies that have cash-slow issues fall beind in their payroll tax payments to the Internal Revenue Service (IRS).  In fact, it might be the number one reason why taxpayers who need help with the IRS end up coming to us.  Now for years, as we have helped taxpayers in New Haven, Connecticut and beyond with payroll tax liabilities.  Things appear to be changing in this area of IRS enforcement.
In 1998 Congress changed the statute to require the IRS to provide a taxpayer an opportunity for a Collection Due Process (CDP) hearing with an IRS Appeals Officer … (0 comments)

new haven ct: Criminal Payroll Tax Issues in New Haven, Connecticut - 05/07/16 07:32 AM
We focus on tax related issues, including civil and criminal tax controversies in New Haven and across Connecticut and New York.  At the latest American Bar Association Tax Section Meeting Acting Assistant Attorney General Caroline Ciraolo confirmed that the Department of Justice Tax Division and IRS Criminal Investigation will continue their combined crackdown on businesses and business owners who fail to properly account for and pay-over payroll tax dollars.  The message was as strong as that delivered last November at the New England IRS Representation Conference at Foxwoods Hotel & Casino by Ciraolo.  You can watch my interview of Caroline Ciraolo … (1 comments)

new haven ct: 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)

new haven ct: 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)

new haven ct: 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)

new haven ct: 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)

new haven ct: 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)

new haven ct: IRS Taxpayer Mistakes New Haven, Connecticut: Biggest Mistake #4 that Taxpayers Make when Dealing with the IRS in New Haven, CT: Not Responding to IRS Notices! - 09/02/12 10:06 PM
We frequently represent clients in IRS exam and Collection matters in New Haven, Connecticut, and know that it is critical for taxpayers to respond to IRS notices timely.  With the IRS’s Automated Under-Reporter System and its Automated Substitute for Return System, it is imperative that taxpayers respond to the IRS quickly when they receive a notice from the IRS.
Failure to respond to an IRS Notice can lead to a number of negative outcomes:
 
 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)

new haven ct: IRS Taxpayer Mistakes New Haven, Connecticut: Biggest Mistake #3 that Taxpayers Make when Dealing with the IRS in New Haven, CT: Filing an Offer-in-Compromise without doing the proper Financial Analysis! - 09/01/12 11:16 PM
We frequently represent clients in IRS Collection matters in New Haven, Connecticut, and can state that the key to filing a successful Offer-in-Compromise (“OIC”) is the upfront analysis that is done to make sure the taxpayer is a viable OIC candidate.  It makes no sense to file OICs wily-nily without any sense of whether they will be accepted or not.
It is a waste of the taxpayer’s money and the IRS’s time. 
We understand you want the IRS gone, and an OIC sounds wonderful.  However you need to understand how the IRS will conduct its analysis.  Nationally, in 2011 the IRS … (1 comments)

new haven ct: IRS Taxpayer Mistakes New Haven, Connecticut: Biggest Mistake #2 that Taxpayers Make when Dealing with the IRS in New Haven, CT: Not Appealing! - 09/01/12 11:13 PM
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)

new haven ct: IRS Taxpayer Mistakes New Haven, Connecticut: Biggest Mistake #1 that Taxpayers Make when Dealing with the IRS in New Haven, CT: Not filing the tax return! - 09/01/12 11:11 PM
We frequently represent clients in IRS examination and Collection cases in New Haven, Connecticut.  One of the biggest mistakes taxpayers (and their tax practitioners) make is to not file a tax return simply because they cannot pay the balance.
We understand the thought process: I cannot pay the tax.  Therefore, if I do not file the tax return, the IRS will not know about it.  I’ll file it with the IRS later when I have the money.
This is maybe the worst mistake a taxpayer in New Haven, Connecticut or elsewhere can make when dealing with the IRS.
The IRS assesses … (0 comments)

new haven ct: Hartford, CT Tax Attorney Wanted - 04/19/11 05:09 AM
<!--StartFragment--> Small boutique tax and estate planning firm in Hartford County seeks experienced tax attorney with some portable book of business. Excellent opportunity for building tax practice with goal for partnership. CPA or LLM preferred. Send resume to: Tax Attorney, P.O. Box 183, Glastonbury, CT 06033-0183.  NO CALLS PLEASE
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Eric L. Green, Your IRS Tax Litigator (Tax Rep LLC)

Eric L. Green

Your IRS Tax Litigator

New Haven, CT

More about me…

Tax Rep LLC

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

Office: 203-285-8545

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