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BBA Centralized Partnership Audit Rules and Bankruptcy
April 3, 2020
In this article Lavar discusses the parallel between bankruptcy and taxes. It appears to be a metaphysical certainty that Congress, when it enacted the new Centralized Partnership Audit Regime ("CPAR") rules contained in 6221 through 6241 of the Internal Revenue Code in 2015, forgot that it had enacted the Bankruptcy Code almost forty years earlier.
IRS Audit Statute of Limitations May Be Extended for Failure to Report Foreign Financial Activity
March 30, 2020
Generally speaking, Section 6501 of the Internal Revenue Code (IRC) provides that the statute of limitations within which the IRS may make an assessment of additional taxes and/or penalties against a taxpayer is three years from the date that the return is filed. For example, if a taxpayer files a 2019 income tax return on April 15, 2020, without extending the “due date” of the return, then the general rule states that the IRS has until April 15, 2023, to assess any additional taxes or penalties for tax year 2019.
The Impact of the Last Known Address Rule on United States Taxpayers
March 10, 2020
The Internal Revenue Service sends various documents and required correspondence to a taxpayer’s “last known address” as required by the Internal Revenue Code. The meaning of the phrase “last known address” is significant, because the legal validity of a notice or document sent by the Internal Revenue Service to the taxpayer, hinges on whether it was sent to a taxpayer’s last known address. Therefore, a taxpayer should take the appropriate measures to ensure that their current mailing address is the address the Internal Revenue Service has on file.
7th Annual Young Tax Lawyers Conference
March 5, 2020
Don’t miss our own Lisa Nelson and Jonathan Amitrano speaking at the 7th Annual Young Tax Lawyers (YTL) Conference held at UCI School of Law on April 17, 2020. The Law Offices of A. Lavar Taylor is proud to be a Diamond Sponsor for this event.
The United States Tax Court Paves Way for Taxpayers to Escape Civil Penalties on Federal Income Tax Assessments
February 20, 2020
When the Internal Revenue Service conducts a tax audit, the Internal Revenue Service often looks to impose an additional tax liability upon the taxpayer. Additionally, in more cases than not, the Internal Revenue Service also imposes civil penalties based on the asserted tax deficiency. Explained differently, when the Internal Revenue Service proposes income tax adjustments as part of an audit, the Service also generally imposes a penalty in addition to the tax liability. Most of the time, the civil penalty is an accuracy-related penalty under Internal Revenue Code Section 6662, which penalizes a taxpayer for his or her negligence for filing an inaccurate return.
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Recent Posts
- April 3, 2020 BBA Centralized Partnership Audit Rules and Bankruptcy
- March 30, 2020 IRS Audit Statute of Limitations May Be Extended for Failure to Report Foreign Financial Activity
- March 10, 2020 The Impact of the Last Known Address Rule on United States Taxpayers
- March 5, 2020 7th Annual Young Tax Lawyers Conference
- February 20, 2020 The United States Tax Court Paves Way for Taxpayers to Escape Civil Penalties on Federal Income Tax Assessments