A “Local Action” is an action that must be brought in the state where the property is located. A taxpayer or third party seeking to clear […]
When the IRS “makes a finding that the collection of such tax is in Jeopardy,” the IRS can make notice and demand for immediate payment and, […]
When can the IRS levy or garnish your wages or bank accounts? In general, the IRS can issue a levy after the tax is assessed (meaning […]
Can The IRS Levy or Garnish My Bank Accounts? If the IRS has satisfied the pre-levy requirements according to federal statutes for a tax liability assessed […]
Does the Full Payment Rule in Federal District Court Tax Refund Suits Include Tax, Penalties, and Interest? It has long been the law that, before a […]
Using Interpreters in Summary Judgment Motions in Federal District Court Interpreters are generally used in two contexts in relation to summary judgment motions in federal district […]
Will the IRS Waive Penalties? In general, with the exception of the fraud penalty, most IRS penalties will not apply where the taxpayer had reasonable cause […]
The Sixth Amendment to the Constitution provides that “[i]n all criminal prosecutions, the accused shall enjoy the right . . . to have the Assistance of […]
Does the IRS Have Discretion to Apply Lower FBAR Penalties? The Ninth Circuit recently found, in United States v. Boyd, that the IRS may only apply […]
When Are Legal Fees Deductible as Employee Business Expenses? In Guill v. Commissioner, 112 T.C. 325 (1999), the United States Tax Court succinctly explained the deductibility […]