News & Analysis as of

Tax Liability Statute of Limitations Income Taxes

McDermott Will & Schulte

Potential Refund Opportunity for Interest and Penalty Amounts Accrued During COVID-19 Federally Declared Disaster

Taxpayers who made payments to the Internal Revenue Service (IRS) that included underpayment interest and/or failure-to-file/pay penalties that accrued during all or part of the period between January 20, 2020, through July...more

Amundsen Davis LLC

Does My Company Qualify for Wisconsin’s Voluntary Disclosure Program?

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Taxes and their applicable laws can be confusing for even the most savvy businesspeople. For any number of reasons, businesses and individuals fall out of compliance with tax reporting requirements and become exposed to...more

Ballard Spahr LLP

Finally Received the Employee Retention Credit? Now What? A Guide to ERC Income Tax Consequences

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It appears that the flood gates have opened and that the IRS is finally processing and paying claims for the employee retention credit (ERC) en masse. After waiting a very long time (often years) with no contact from the IRS,...more

Freeman Law

Tax Court in Brief | Fairbank v. Comm’r | Reporting Obligations for Foreign Trust Income and Ownership; Statute of Limitations

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Summary:  At its core, this 31-page opinion regards married U.S. citizen taxpayers, Leigh Fairbank (Leigh) and Barbara Fairbank (Barbara), challenge to deficiency notices issued for the tax years in issue (2003 through 2009...more

Freeman Law

Tax Court in Brief | Schwartz v. Comm’r | Collection Due Process; Credit Election Overpayment; Quintessential Tax Procedure

Freeman Law on

Schwartz v. Comm’r, T.C. Memo. 2022-125| December 21, 2022 | Vasquez, J. | Dkt. No. 17291-14L - Short Summary:  Eric Schwartz (“Schwartz”) and his spouse divorced.  Pursuant to those divorce proceedings, the state court...more

Gerald Nowotny - Law Office of Gerald R....

Ten Years After - The IRS Collection Statute of Limitations

I was a youngster for the Woodstock Music and Art Fair commonly known as Woodstock took place in Bethel, NY between August 15-18, 1969. Frankly, I never knew anyone growing up in the Canal Zone that attended in person. The...more

Freeman Law

Criminal Tax Statutes of Limitations and Suspensions: 18 U.S.C. § 3292 and the Fifth Circuit’s Decision in Pursley

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In civil and in criminal cases, the Government must generally act within a certain prescribed time to take action against taxpayers. In legal parlance, this period of time is known as the “statute of limitations.” The...more

Freeman Law

Protective Refund Claims: Preserving the Right to a Tax Refund

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When is a protective refund claim available?  Taxpayers often face uncertain outcomes in litigation or business transactions, giving rise to contingent tax refund claims.  For example, if a pending lawsuit ends in a favorable...more

Gray Reed

Statute of Limitations in Tax Cases – The Basics

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What is the Statute of Limitations? - The Internal Revenue Code limits the time in which the government may assess tax. There are two civil statutes of limitations.  The first is the period during which the IRS can assess...more

Freeman Law

Missed Window—Taxpayer Loses Chance to Sue IRS on Claim for Refund

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In The Merry Wives of Windsor, William Shakespeare penned the famous line: “Better three hours too soon than a minute too late.” And such sentiments of time are certainly true in the tax world. One minute late may have...more

Freeman Law

Can You Transfer Assets to Avoid Paying Taxes to the IRS?

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In many cases, taxpayers attempt to transfer assets or property to third persons to shield those assets and property from the federal tax lien or federal tax levy. Predictably, the IRS has various tools at their disposal to...more

Freeman Law

The Tax Court in Brief - July 2021

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of July 5 – July 9, 2021 - Peterfreund v. Commissioner,...more

Freeman Law

IRS Publishes Proposed BBA Regulations on Special Enforcement Matters

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Over 5 years ago, then President Obama ushered in sweeping changes to the method and manner in which partnerships are audited and partnership tax is assessed and collected through his signing of H.R. 1314, the Bipartisan...more

Foster Garvey PC

The IRS Will Put the American People First — No, Really (But Only for a Limited Time)

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Wednesday, March 25th, in the wake of the recent decision by the Internal Revenue Service (“IRS”) to extend the income tax filing and payment deadlines to July 15, 2020, it announced a new taxpayer-friendly program called the...more

Burr & Forman

IRS Announces New “People First Initiative” Suspending Many Important Federal Tax Compliance Dates and Certain Tax Collection...

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March 25, 2020 – The IRS announced a major suspension of many “tax compliance” dates and tax collection measures. Published in IRS Information Release 2020-59 as the “People First Initiative”, the IRS announced that it is...more

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