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BBA Partnership Tax Provisions and Bankruptcy– A Recipe for Disaster, Part 1

May 27, 2020

Some of us practitioners are old enough to have endured the transition to the TEFRA Partnership audit provisions from the unwieldy pre-TEFRA rules that required the IRS to audit the tax returns of all partners in a tax partnership in order to assess deficiencies resulting from adjustments to Forms 1065 filed by those partnerships.  That transition required a considerable learning curve.

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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.

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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.

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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.

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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.

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