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By Eric L. Green, Your IRS Tax Litigator
(Tax Rep LLC)
Comments 2
You probably have seen the IRS has now issued John Doe Summonses against other cryptocurrency exchanges with the goal of obtaining taxpayer information.  On this week’s podcast Eric is joined by Kostelanetz & Fink’s Don Fort and Larry Sannicandro to discuss the impact of the IRS and DOJ summonses, and what it means for taxpayers and enforcement.  In particular, Don as former Chief of IRS Criminal Tax Division discusses what is going on at the IRS, and he and Larry explain what taxpayers should be considering doing right now if they have in fact dealt in virtual currency and have not reported the transactions.Listen to the episode on Spotify, Google Podcasts, ITunes, Apple Podcasts or here on the podcast homepage: https://taxrepllc.com/subscribe-tax-rep-network-podcast/  Want to contact:...
By Eric L. Green, Your IRS Tax Litigator
(Tax Rep LLC)
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Joining Eric on this week's Tax Rep Network Podcast is none other than the former National Taxpayer Advocate, Nina Olson.  With so many taxpayers in trouble it is worth discussing the impact of economic hardship, what it means for taxpayers and the IRS and what the IRS can and cannot do to those taxpayers. Nina also discussed the issue around Offset Bypass Refunds, which is how uncollectible taxpayers that owe money can still get their refunds. Listen in on this can’t miss episode and learn some new strategies that you can use to help taxpayers weather the ongoing COVID fallout.  Want to contact Nina? Check out the Center for Taxpayer Rights: https://taxpayer-rights.org/ Looking for the guidance on Offset Bypass Refunds? Click here: https://www.irs.gov/pub/lanoa/pmta_2013-13.pdf  Want t...
By Eric L. Green, Your IRS Tax Litigator
(Tax Rep LLC)
Comments 0
We represent taxpayers before the IRS and Department of Justice Tax Division, and have spoken frequently about the IRS increased use of both AI and John Doe Summonses to identify taxpayers who have either evaded reporting income and paying taxes, or those that have failed to disclose virtual currency in their financial affidavits, like with Offers-in-Compromise.Because of the IRS's efforts criminal tax referrals from the Collection Division are up 42% so far this year!Check out our podcasts #91 and 93 on this topic here:  https://taxreptoolbox.com/tax-rep-network-podcast-main-page/ Today a federal court in the District of Massachusetts entered an order today authorizing the IRS to serve a John Doe summons on Circle Internet Financial Inc., or its predecessors, subsidiaries, divisions, a...
By Eric L. Green, Your IRS Tax Litigator
(Tax Rep LLC)
Comments 0
Back to join Eric is Steven Toscher and Michel Stein (Episode 32) to update us on IRS enforcement around virtual currency, what its goals are and what taxpayers can expect. Listen in as our experts update you on what has quickly become an IRS and Department of Justice enforcement priority.Catch the episode on ITunes, Apple Podcasts, Spotify, or here on our Tax Rep Network Podcast Page! 
By Eric L. Green, Your IRS Tax Litigator
(Tax Rep LLC)
Comments 1
In 2011, a sensational new black market website known as the “Silk Road” emerged on the dark net. This “Amazon of Illegal Drugs” was the brainchild of a mysterious, libertarian intellectual operating under the avatar “The Dread Pirate Roberts.” Promising its users complete anonymity, and total freedom from government regulation or scrutiny, Silk Road became a billion-dollar digital drugs cartel. Operating behind the special browser TOR and using on bitcoin, the criminal behind Silk Road would be taken down by a tenacious new special agent from the IRS assigned to the case. Joining Eric on this week’s podcast is that special agent, Gary Alford, to give is a glimpse into the puzzle that was Silk Road and his determination to find the clues necessary to crack the case.Check it out here: ht...
By Green & Sklarz LLC, Connecticut's Firm for Business Law
(Green & Sklarz LLC)
Comments 0
In 2011, a sensational new black market website known as the “Silk Road” emerged on the dark net. This “Amazon of Illegal Drugs” was the brainchild of a mysterious, libertarian intellectual operating under the avatar “The Dread Pirate Roberts.” Promising its users complete anonymity, and total freedom from government regulation or scrutiny, Silk Road became a billion-dollar digital drugs cartel. Operating behind the special browser TOR and using on bitcoin, the criminal behind Silk Road would be taken down by a tenacious new special agent from the IRS assigned to the case. Joining Eric on this week’s podcast is that special agent, Gary Alford, to give is a glimpse into the puzzle that was Silk Road and his determination to find the clues necessary to crack the case.Check it out here: ht...
By Green & Sklarz LLC, Connecticut's Firm for Business Law
(Green & Sklarz LLC)
Comments 0
On February 23, 2021, the U.S. Tax Court rule in favor of our client that acquisition of credit card reward points, no matter how many the receive, is not a taxable event.  In Anikeev v. Commissioner, the IRS tried to tax credit card reward points that the taxpayer received claiming they were “cash equivalents” because the taxpayer purchased gift cards with his credit card, which generated rewards points, and then used the gift cards to purchase money orders, which the taxpayer then deposited in his bank account.  The Tax Court ruled the transaction was not a taxable event: “Reward [points] petitioners received were not notes, but they were commitments by [the credit card issuer] to allow petitioners credits against their card balances. Respondent’s analysis leaps to the cash equivalenc...
By Green & Sklarz LLC, Connecticut's Firm for Business Law
(Green & Sklarz LLC)
Comments 0
Given that the focus of my practice is civil and criminal taxpayer representation, I am excited to be teaching again at the National Association of Tax Professionals TaxCon 2021! Join us for this terrific virtual annual conference where I will be covering "Dealing with the IRS Collection Division", surely a hot topic for later this year when the IRS begins issuing levies again.Hope to see you there!Check out the conference site here!EricEric L. Green, EsqGreen & Sklarz LLCOne Audubon Street, 3rd FloorNew Haven, CT 06511www.gs-lawfirm.comEmail: egreen@gs-lawfirm.comPh. (203) 285-8545 
By Eric L. Green, Your IRS Tax Litigator
(Tax Rep LLC)
Comments 0
On this week's Tax Rep Network Podcast I discuss the impact of the IRS's use of AI. If you listened to the episode with Deputy Commissioner of SB/SE Darren Guillot you heard about how the IRS is using AI to target taxpayers who have failed to disclose assets on their 433 (Offers, CNC, etc.). It is episode 91 if you missed it. On this episode I discuss what that means and how we need to change our collection practice intakes to protect us from our client, and our client's from themselves!   https://taxrepllc.com/tax-rep-network-podcast-episode-93-irs-enforcements-impact-on-our-collection-practice-erics-takeaway/  
By Green & Sklarz LLC, Connecticut's Firm for Business Law
(Green & Sklarz LLC)
Comments 0
On January 11, 2021 the U.S. District Court in Connecticut decided USA v. Kaufman and held that the maximum penalty for unintentionally failing to file FBARs is $10,000 per year. Not $10,000 per account. This is a major victory for taxpayers as the IRS has sought to use the non-willful FBAR penalty to exact large penalties from taxpayers, many of whom did not even know they had foreign accounts, who made honest mistakes. Trial counsel for the taxpayer will discuss the impact of this case on FBAR litigation and provide an update of best practices for offshore compliance.   Register for FREE here and join us for this gfree webinar: https://gs-lawfirm.com/program-20210211-offshore-update/  DETAILS: The Program is FREE to Register! The Program is 1pm – 2pm Eastern via LIVE WEBCAST The Prog...
By Eric L. Green, Your IRS Tax Litigator
(Tax Rep LLC)
Comments 2
The pandemic continues to rage and new stimulus payments are going out, with a possible third round coming. Threats to levy have been mailed and Notices of Federal Tax Liens have been filed. So when will the hammer fall? When can taxpayers expect enforcement to rebound and come after them? Join us for an update with Darren Guillot, SB/SE Deputy Commissioner as he explains where the IRS is right now in terms of enforcement, how the IRS civil enforcement is working with the new Office of Fraud Enforcement and the results they are seeing, and what we can expect in the rest 2021.Check out this week's podcast here: https://taxrepllc.com/tax-rep-network-podcast-episode-91-irs-enforcement-in-2021-a-conversation-with-darren-guillot/   
By Eric L. Green, Your IRS Tax Litigator
(Tax Rep LLC)
Comments 0
Yesterday, a District Court Judge in Connecticut ruled in favor of our client at summary judgment and found that the nonwillful penalty for failure to file an FBAR is capped at $10,000 per form, not per account, as had been argued by IRS and and DOJ. This was a matter of first impression for the Court and the ruling will impact many taxpayers. To date, the issue had only been decided by two other courts and they were divided on the issue.Ypou can read the decision here: United States v. Kaufman Questions about this or other tax litigation matters?  Contact us at either egreen@gs-lawfirm.com or (203) 285-8545.Eric L. GreenGreen & Sklarz LLCOne Audubon Street, 3rd FloorNew Haven, CT 06511Ph. (203) 285-8545egreen@gs-lawfirm.comwww.gs-lawfirm.com 
By Eric L. Green, Your IRS Tax Litigator
(Tax Rep LLC)
Comments 0
PPP-2: The New Rules and Tax ConsequencesTuesday, January 12, 2021 | 1pm – 4pm Eastern | via Live Webinar   On December 21st Congress passed a $2.3 trillion spending bill, which included about $900 billion of which is directed to relief programs, including a new round of PPP loans (PPP-2).  On January 6th, the SBA release interim guidance for implementation of PPP-2.  This program will provide a detailed review of the PPP program generally, and how the new guidance applies to businesses seeking either 1st or 2nd draw PPP loans.    We will also review the tax related provisions, such as the expanded Employee Retention Tax Credit (ERTC) and expenses paid with PPP loans. PPP loans generally Second Round of PPP Funding  Clarification of Tax Treatment of PPP Loans  Employee Retention Tax Cre...
By Eric L. Green, Your IRS Tax Litigator
(Tax Rep LLC)
Comments 0
Given how wonderful 2020 has been, Tax Rep Network thought we would throw 2020 out the window and ring in the New Year with fun filled webinar designed to celebrate the IRS’s finest!Ever dealt with an auditor that you begin to realize immediately must be named Lucifer? The point of an audit, according to the IRS itself, is to check on how the taxpayer is doing in respect to their returns and reporting and use this time as an educational opportunity. Yet sometimes there are examiners who do not seem to understand this and have decided it’s a time to torture you and your client. Trust us, you do not need to take their abuse!Meanwhile, working out a collection alternative with the IRS is not painful. Well, at least it shouldn’t be. However, every now and then you meet a Revenue Officer who...
By Eric L. Green, Your IRS Tax Litigator
(Tax Rep LLC)
Comments 0
Solving Tax Debts: Economic Hardship in the Time of COVID. On December 22nd I (Eric Green) and The Nina Olson, our former IRS National Taxpayer Advocate, will be doing a special two-hour webinar on how to solve your client's tax debts in this particularly difficult economic time. We are asking you to pay $35 because it is a fund raiser, and ALL PROCEEDS go to the Center for Taxpayer Rights.Low Income Taxpayers are being hammered right now, and the Low Income Taxpayer Clinics are getting over-run. Join us for a fun program, get two CE/CPE credits, and help low income taxpayers everywhere.So please register here, help people that need it it this holiday season, and we will see you on December 22nd: https://taxrepllc.com/program-20201222-ctr-solving-tax-debts/?inf_contact_key=acd41b51bfd32...
By Eric L. Green, Your IRS Tax Litigator
(Tax Rep LLC)
Comments 0
Listen in on the interview with the IRS’s new Director of Fraud Enforcement Damon Rowe and Carolyn Schenk, IRS National Fraud Counsel, by Bryan Skarlatos of Kostelanetz & Fink, LLP.  Posted today on the Tax Rep Network.Listen here: https://taxrepllc.com/tax-rep-network-podcast-episode-87-an-update-from-the-irss-new-fraud-czars-damon-rowe-carolyn-schenk-2020-irs-representation-conference/ Want to listen and watch the ENTIRE 2020 IRS Representation Conference? Download ALL the Recordings and Handouts! Purchase now at a special rate! – https://irsrepconference.com/2020-irs-representation-conference-recordings-and-handouts-purchase/—
By Eric L. Green, Your IRS Tax Litigator
(Tax Rep LLC)
Comments 0
Join Caroline Ciraolo of Kostelanetz & Fink, LLP as she discusses what is happening at IRS Office of Chief Counsel with our IRS Chief Counsel, Michael Desmond, from the New England IRS Representation Conference.Catch the podcast interview here: https://taxrepllc.com/tax-rep-network-podcast-episode-86-the-view-from-irs-office-of-chief-counsel-michael-desmond-2020-irs-representation-conference/ Want to listen and watch the ENTIRE 2020 IRS Representation Conference? Download ALL the Recordings and Handouts! Purchase now at a special rate! – https://irsrepconference.com/2020-irs-representation-conference-recordings-and-handouts-purchase/—Want to build an IRS Rep Practice?  Join Tax Rep Network at TaxRepLLC.comCall the IRS in under three minutes with ENQ by signing up here: https://callenq.c...
By Eric L. Green, Your IRS Tax Litigator
(Tax Rep LLC)
Comments 0
Tax practitioners are governed by many various rules of ethics, including the IRS Regulations known as “Circular 230”. This program will cover the Circular 230 rules and everyday ethical issues that arise for private practitioners.But what about the IRS’s employees? What ethical rules constrain them from running roughshod over taxpayers?There are several bodies that govern IRS employees, including the Taxpayer Bill of Rights, and the IRS is policed by the Treasury Inspector General for Tax Administration (“TIGTA”). This special ethics program will cover what to do if the IRS violates the taxpayer’s rights, and what practitioners can do to protect their taxpayers and obtain a proper resolution.In this special workshop, you will learn: Understand the ethics rules that apply to tax practic...
By Eric L. Green, Your IRS Tax Litigator
(Tax Rep LLC)
Comments 0
So what is an IRS Offer-in-Compromise?  I mean really?When the IRS calculates the RCP (Reasonable Collection Potential) of a client, what does that mean?  Does the IRS expect the client to liquidate their investments?  Sell or remortgage their home?  What if the client cannot tap the equity...then what?Listen in on this week's Tax Rep Network podcast for a brief but to the point analysis of the IRS's Offer-in-Compromise program by Eric Green, and you will understand why we get more than 90% of our Offers accepted!Eric L. Green, Esq.Green & Sklarz LLCOne Audubon Street, 3rd FlNew Haven, CT 06511Ph. (203) 285-8545egreen@gs-lawfirm.comwww.gs-lawfirm.com 
By Eric L. Green, Your IRS Tax Litigator
(Tax Rep LLC)
Comments 1
When business suffers taxpayers begin cheating. So what can you do if your client knows about tax crimes being committed? They can strike a blow for justice, the American tax system, and get paid doing it. Nothing more American than that!Fresh off the Tax Rep Network Podcast and as a warm up to the New England IRS Rep Conference, Attorneys Mike Villa and Eric Green will host a special one-hour program will they review the IRS Whistleblower program, discuss how your client can bring a claim that stands the best chance of receiving an award, and how the system ACTUALLY works!Date: November 10th Cost: FREECPE/CE: 1 Credit for EAs and CPAs Register Here: https://taxrepllc.com/promo-20201110-how-to-bring-whistleblower-claim/?inf_contact_key=4ab9500fec563c3c6dc09f1d5960d1b1 

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