Three recent Federal Court cases, Premier Tech v. United States, No. 2:20-cv-890-TS-CMR (D. Utah 2021); Intermountain Electronics v. United States, No. 2:20-cv-00501-JNP (D. Utah 2021); and Harper v. United States, 847 F. Appx. 408 (9th Cir. 2021), remind taxpayers of…
Continue Reading “Specificity” Very Important in Claim for Refund Requests

I have written previously on this Blog and for Cointelegraph on the Jarrett v. Commissioner case filed on May 26 with a Tennessee Federal District Court (Case No. 3:21-cv-00419), whereby the taxpayers sought a refund of taxes they had paid…
Continue Reading Important IRS Development in the Property Characterization of All Cryptocurrency

Jeopardy assessments for tax collection are rare, but they are a tool available to the IRS in extraordinary circumstances. Jeopardy assessments stand outside the normal IRS assessment procedures. In general,
and in extraordinary circumstances, jeopardy assessments permit the IRS to…
Continue Reading The Nuts and Bolts of IRS Jeopardy Assessments for Tax Assessment Purposes

IRS Appeals Conferences may now include additional participants. After the conclusion of an IRS Appeals pilot program, the results suggest that IRS Appeals benefits from including examination teams and Chief Counsel attorneys to engage with taxpayers and their representatives at…
Continue Reading IRS Appeals is Changing and May Not Be for the Better

Normally, an Innocent Spouse Determination Letter denying relief is final unless a taxpayer files a Tax Court Petition to challenge the denial. If that Tax Court Petition deadline (90 days from the Innocent Spouse Determination Letter) is missed, then the…
Continue Reading Timeliness of Tax Court Petitions for Innocent Spouse Claims

As a result of the IRS campaign against cryptocurrency tax noncompliance, it has received more than 1,000 amended tax returns, collected $13 million in taxes from crypto holders with more than $20,000 of transactions, and collected another $12 million from…
Continue Reading Results of IRS Cryptocurrency Campaign

The IRS is now using data analytics and article intelligence to access billions of crypto transactions in the digital world and make the process more efficient for IRS Criminal Investigators. Once your cryptocurrency becomes fiat currency and once it goes…
Continue Reading IRS Advancements in Cryptocurrency Tracking