stamford ct: Tax Deductions in Stamford CT: The IRS & Unsubstantiated Deductions - 12/04/16 08:34 AM
The focus of our practice is on civil and criminal tax controversy, and we are often asked to defend taxpayers under IRS examination. One of the areas focused on by the IRS are the expenses claimed by taxpayers against their income. Taxpayers need to understand that they have to carry the burden of showing they are entitled to a deduction claimed on their tax return.
Whether taxpayers live in Stamford, Connecticut, New York city or elsewhere, a significant hurdle faced by taxpayers with tax issues involves providing enough documentation to substantiate claimed expenses, deductions, and various other tax attributes. Some recent tax court … (0 comments)

stamford ct: LLCs in Stamford Connecticut: Connecticut Adopts the Uniform LLC Act - 05/05/16 01:13 AM
We spend a significant amount of time representing Connecticut businesses in all sorts of transactions.  Last night on May 4, 2016 the Connecticut State Senate voted to adopt the Uniform Limited Liability Act, impacting tens of thousands of Connecticut Limited Liability Companies (the Connecticut House of Representatives having already previously voted to adopt the Act).  Upon Governor Malloy’s signing the bill (which is expected shortly) many Connecticut businesses will want to review the changes and see if the new Act operates in a way that works for their businesses.  If not client’s should a written operating agreement in place before the … (0 comments)

stamford ct: Streamlined Compliance for Non-Resident U.S. Taxpayers, Part IV - 01/17/14 09:05 PM
The focus of our practice is civil and criminal taxpayer representation, as well as assisting taxpayers with foreign bank account issues, and we see many taxpayers in Stamford, Connecticut who are dealing with reporting foreign bank accounts and their failure to file United States Tax returns while living abroad.  
Part I of this series discussed the new streamlined compliance procedures for U.S. taxpayers living abroad have failed to timely file U.S. federal income tax returns or Reports of Foreign Bank Account Reports (FBARs), Form TD F 90-22.1, but have recently become aware of their filing obligations and now seek to come … (0 comments)

stamford ct: Streamlined Compliance for Non-Resident U.S. Taxpayers, Part III - 01/17/14 08:55 PM
The focus of our practice is civil and criminal taxpayer representation, as well as assisting taxpayers with foreign bank account issues, and we see many taxpayers in Stamford, Connecticut who are dealing with reporting foreign bank accounts and their failure to file United States Tax returns while living abroad. 
Part I of this series discussed the new streamlined compliance procedures for U.S. taxpayers living abroad have failed to timely file U.S. federal income tax returns or Reports of Foreign Bank Account Reports (FBARs), Form TD F 90-22.1, but have recently become aware of their filing obligations and now seek to … (0 comments)

stamford ct: Streamlined Compliance for Non-Resident U.S. Taxpayers, Part II - 01/17/14 08:44 PM
The focus of our practice is civil and criminal taxpayer representation, as well as assisting taxpayers with foreign bank account issues, and we see many taxpayers in Stamford, Connecticut who are dealing with reporting foreign bank accounts and their failure to file United States Tax returns while living abroad.  
Part I of this series discussed the new streamlined compliance procedures for U.S. taxpayers living abroad have failed to timely file U.S. federal income tax returns or Reports of Foreign Bank Account Reports (FBARs), Form TD F 90-22.1, but have recently become aware of their filing obligations and now seek to come … (1 comments)

stamford ct: Streamlined Compliancefor Non-Resident U.S. Taxpayers, Part I - 01/17/14 08:35 PM
The focus of our practice is civil and criminal taxpayer representation, as well as assisting taxpayers with foreign bank account issues, and we see many taxpayers in Stamford, Connecticut who are dealing with reporting foreign bank accounts and their failure to file United States Tax returns while living abroad. 
These new streamlined filing compliance procedures for non-resident U.S. taxpayers are being implemented in recognition that some U.S. taxpayers living abroad have failed to timely file U.S. federal income tax returns or Reports of Foreign Bank Account Reports (FBARs), Form TD F 90-22.1, but have recently become aware of their filing … (1 comments)

stamford ct: 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)

stamford ct: Criminal IRS Tax Referrals in Stamford, CT and New York, NY - 11/27/13 09:58 PM
The focus of our practice is civil and criminal taxpayer representation, and see many taxpayers in Stamford, Connecticut referred to the IRS Criminal Investigation division because of shoddy bookkeeping.  It is critical that taxpayers maintain good records or face serious tax bills, or even criminal tax prosecution.
Many IRS criminal tax cases begin as routine civil IRS examinations and, when the examiner is confronted with either a lack of records or bookkeeping records that cannot be easily reconciled to the federal IRS tax return, thoughts of a referral to the criminal investigation division begin to grow.
The goals for any taxpayer … (0 comments)

stamford ct: 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)

stamford ct: 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)

stamford ct: 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)

stamford ct: 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)

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 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)

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 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)

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! - 01/16/12 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)

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 12:02 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 01:39 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 07:56 AM
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 02:18 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 02:00 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)

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

Eric L. Green

Your IRS Tax Litigator

Stamford, CT

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Green & Sklarz LLC

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

Office: 203-285-8545

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