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When I first studied to take the Tax Court entrance exam, it was stressed that I would almost certainly never see any "Perry Mason moments" in a Tax Court trial.
That being said, while attending a trial session locally, I recall one petitioner (a doctor caught up in a bogus tax shelter scheme)...
If you have a CPA preparing these K1-s, why aren't you asking THEM this question? Because as a tax professional, if I were preparing the return and I had that information available, it would be disclosed appropriately. Because, you know, professional.
It sounds to me like you've never done...
I read posted Tax Court opinion every day, and it amazes me how often when even after being given not so subtle warnings from the judge about potential penalties for advancing these arguments, that taxpayers will up to and through the conclusion of the trial advance frivolous arguments (usually...
I don't like to get caught up in credential boasting and male sex organ wagging. The CPA is right but the prohibition is also codified in Title 31 of the US Code. The problem you run into in a situation like this is defining what is considered US Treasury bond interest. Some states (including...
Well she got a yellow pre-warrant notice card in the mail today from a specific town showing a hand written amount and a hand written note stating the specific charge. I looked it up and it's a Class C misdemeanor and the stated fine owed is roughly $250. I'm loathe to tell her to pay it where...
I can tell you that as part of tax planning this year, I recommended Roth 401(k) contributions rather than regular ones because the tax benefit of the deduction for the traditional contribution wasn't worth it where the taxpayers were in the lower tax brackets.
I posted my viewing of her google map locator history in another post. As for her remembering, I'll just say that to call her geographically challenged is an insult to people who struggle with maps. Having driven cross country myself once, I could tell you exactly what major road I was on in...
Says it was handed to her and she gave a signature.
It was east to west, north of Dallas but I don't think it was on an interstate. Checking the google map phone locator record, she entered the state near Texarkana, went through Lubbock, and exited around El Paso. Best guess would be between...
Significant other was driving in Texas. Stopped late at night, best I can tell from what I'm told, they opened the trunk, found empty beer cans in it, charged her with an open container and nothing else. I wasn't there, that's what I'm told and supposedly she is/was supposed to have a court...
I call people like that former clients. I've also had non-clients approach me about representing them in Tax Court over relatively small amounts, small enough to be less than my retainer for taking the case, because they believe appearing in Tax Court to contest an assessment is akin to...
I would imagine the penalty in this situation would be assessed as part of a deficiency notice on the shareholder, where the shareholder would then be able to contest it in Tax Court. Any other method used to pursue it would mean there is something bigger going on.
Even if IRS decided to pursue a shareholder under transferor liability, in court the burden of proof is on the IRS. I can't see IRS counsel wanting to spend any real resources litigating and pursuing an 1120S late filing penalty.
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