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Rivkin Radler LLP

Drop & Swap Like-Kind Exchange Passes Muster in New York

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New York’s personal income tax law, like that of other states, conforms with the federal system of income taxation. The reason typically given for such conformity is to simplify tax return preparation, improve compliance and...more

Freeman Law

Posts, Profits, & Penalties | Tax Law & Social Media | Part 4

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As discussed in Part 2, there are many ways social media creators earn income. Social media income, like all income, needs to be reported on federal tax returns....more

Fox Rothschild LLP

IRS Layoffs May Mean Longer Waits, Audit Delays and Tax Court Battles

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The Internal Revenue Service (IRS) is expected to lay off approximately 7% of its workforce in the coming weeks, with the possibility of further reductions. It remains unclear which divisions will be most affected or whether...more

Allen Barron, Inc.

The Appeal of an IRS Audit is Based Upon the Audit's Examination File

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Did you know the appeal of an IRS audit is based upon the IRS examination file record of the audit itself? When the IRS produces its "Notice of Determination" at the end of an audit, a very important door closes: the ability...more

Foodman CPAs & Advisors

Correo Del IRS

En su mayor parte, los contribuyentes no quieren recibir correo del IRS ni abrir correo del IRS. Es por eso por lo que el IRS emitió el Consejo Fiscal (“Tax Tip”) 2024-45 el 6 de mayo de 2024 para informar a los...more

Foodman CPAs & Advisors

Mail From The IRS

For the most part, Taxpayers do not want to receive mail from the IRS or open mail from the IRS. This is why IRS issued Tax Tip 2024-45 on May 6, 2024 to let taxpayers know what taxpayers should do if they receive mail from...more

Rivkin Radler LLP

Missing the Tax Court’s 90-Day Deficiency Deadline – Now What?

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Over the years, I have observed there is only one thing that a taxpayer fears more than being notified by the IRS that their income tax return for a particular taxable year has been selected for audit, and that is being...more

Foodman CPAs & Advisors

¿Es Un Hobby O Negocio?

Los contribuyentes pueden enfrentarse a la pregunta: “¿Es un hobby o negocio?”. El IRS afirma que: “a veces la línea entre tener un hobby y administrar un negocio puede ser confusa, pero conocer la diferencia es importante...more

Foodman CPAs & Advisors

Is It A Hobby Or Business?

Taxpayers may be faced with the question: “Is it a hobby or business?” The IRS states that: “sometimes the line between having a hobby and running a business can be confusing, but knowing the difference is important because...more

McDermott Will & Emery

OTA Finds CDTFA’s Audit Methodology Arbitrary

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In Appeal of Colambaarchchi (OTA Case No. 21017152; 2023-OTA-302), a California-based retailer was audited by the California Department of Tax and Fee Administration (CDTFA) for years 2016 through 2019. Upon audit, CDTFA...more

Venable LLP

Taxpayers and Tax Preparers, Beware of Automated Notices of Deficiency

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The IRS has increased its practice to issue Notices of Deficiency without an audit. For example, if there is a mismatch between what was reported on a Form 1099 for a taxpayer and the income shown on the taxpayer's return, or...more

Holland & Knight LLP

Willful or Non-Willful? That Is the Question: IRS Rejects Non-Willful Certification

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In Flint v. United States, 2022 WL 3593826 (Fed. Cl. 2022), the court held that the executors of an estate could not recover a six-figure "Title 26 miscellaneous offshore penalty" (MOP) the decedent paid to the Internal...more

Rivkin Radler LLP

Reasonable Compensation Meets The Principal Shareholder of a C Corp

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Double Tax- The shareholders of C corporations have long sought legitimate operational and transactional structures by which they may reduce the double tax hit that is realized when such a corporation distributes its...more

White and Williams LLP

2022 Tax Filing Season: Nine Things You Need to Know

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The 2022 tax season is upon us. With what promises to be an unusual tax filing season, below are nine updates and tips to keep in mind. 1. Tax Returns are Lagging. On January 12, the National Taxpayer Advocate issued its...more

Troutman Pepper Locke

Do You Know Who Your Partnership Representative Is? - Tax Update Volume 2019, Issue 1

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The new partnership audit rules apply to tax years beginning in 2018. While the new rules eliminate the need for a tax matters partner, that role is replaced with a new role called the partnership representative (PR). ...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 6, Issue 10

State Tax Department Releases Draft Article 9-A Nexus Regulations Under Corporate Tax Reform - The New York State Department of Taxation and Finance has released draft amendments to the Article 9-A corporate franchise...more

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