Income Tax Issues
All Articles / Income Tax Issues / Tax Articles

What’s in a Name
A Brief History of the “Internal” Revenue Service

What Keeps Me up at Night Once upon an early morning dreary, while I pondered weak and weary…What's in a name? At about 2:45 this morning, while I was writing a post on gross income (soon, my friends), the thought crossed my mind, what makes the Internal Revenue Service and the Internal Revenue Code internal? Why not simply the Revenue Service and the Revenue Code? So, I thought to myself, what’s in a name: the “Internal” Revenue Service? Back in the Day Running a nation is expensive. Interstate highways do not build themselves, B-52 bombers do not grow on trees, and the Internal Revenue Code did not write itself. In 1791, George Washington and his new Congress realized, as angry as they were about the “Intolerable” Acts,” such as the stamp tax and the tax on tea (see, e.g., the Boston Tea Party), that taxes were a necessary evil. Not…

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December 9, 2024
Procedural Issues
All Articles / Income Tax Issues / Procedural Issues / Tax Articles

What Every Taxpayer Must Understand about IRS Enforced Collection
A Comprehensive Guide from Assessment to Levies

In this comprehensive taxpayer's guide to enforced collection, Briefly Taxing walks you through what every taxpayer must understand about IRS enforced collection.  The IRS’s authority to enforce the collection of taxes through liens, levies, and other means is a formidable aspect of the United States tax system, often evoking a (well-deserved) sense of dread among taxpayers. Enforced collection is not just a theoretical concept; it is the practical reality of the IRS’s power to ensure compliance with tax obligations. This article delves into the procedural intricacies of IRS enforced collection, exploring how the IRS assesses taxes, imposes liens, and executes levies against delinquent taxpayers who fail to meet their federal tax obligations (and who are utterly unwavering in their commitment to avoid paying Uncle Sam). Understanding the procedure and mechanisms of IRS enforced collection is essential for both taxpayers and tax professionals, alike. The mechanisms underlying IRS enforced collection efforts…

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September 2, 2024
Guest Article
All Articles / Guest Article

Redefining Your Financial Outlook for Greater Life Success
Guest Post

Redefining Your Financial Outlook for Greater Life Success Guest Writer:  Michael Longsdon of ElderFreedom.net* It's a powerful realization that our financial success is deeply intertwined with our money mindset. This article will guide you through the steps to rewire your perception of money and to redefine your financial outlook, opening up new possibilities for overall life success. By shifting your mindset and embracing a healthier relationship with money, you can unlock greater abundance and financial freedom. Take control of your financial future and start creating the life you've always envisioned. Unmask Financial Misconceptions Embarking on this transformation begins with identifying and challenging the negative beliefs about money that are holding you back. These could range from "money is evil" to "wealth isn't in my destiny." Replace these disempowering notions with positive affirmations that align with your aspirations. Remember, you have the power to shape your financial future. Start today and take control…

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November 28, 2023
Guest Article
All Articles / Business Related Issues / Tax Articles

Ultimate Guide to Managing Business Finances for Entrepreneurs
Guest Post

Guest Writer:  Michael Longsdon of ElderFreedom.net* As an entrepreneur, managing the finances of your business can be a daunting task, which is why this Guide to Managing Business Finances for Entrepreneurs was created. It is not uncommon to feel overwhelmed, especially if you lack experience in finance. However, good financial management is essential to keep your business afloat and thriving. Below are some tips to help entrepreneurs struggling with business finances. Easier Payment Processes One of the biggest challenges faced by entrepreneurs is getting paid. Payment processing can be a tedious process, taking up time that could be spent on more productive activities. Thankfully, there are payment processing solutions that can make payment acceptance and processing easier than ever. Today, there are many payment processing systems available that offer different features and benefits. These payment systems are easy to set up and integrate into your existing systems, saving you time…

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June 26, 2023
Procedural Issues
Memorandum Opinions / Procedural Issues / Tax Opinions

Norberg v. Commissioner
T.C. Memo. 2022-30

On April 5, 2022, the Tax Court issued a Memorandum Opinion in the case of Norberg v. Commissioner (T.C. Memo. 2022-30). The primary issue presented in Norberg v. Commissioner was whether the settlement officer abused its discretion in upholding a notice of intent to levy and denying the petitioners’ request to be placed in currently not collectible status (despite having the ability to make payments). Held:  Background to Norberg v. Commissioner In February 2019, the petitioners filed a delinquent Federal income tax return for 2016. That return reported a tax liability of $42,000. The petitioners did not enclose full payment with the return, and as of September 2019, their outstanding liability for 2016 was about $9,200. In September 2019, in an effort to collect this liability, the IRS issued a levy notice to the petitioners, and they timely requested a CDP hearing. They expressed interest in a collection alternative, checking…

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January 24, 2023
Income Tax Issues
Income Tax Issues / Memorandum Opinions / Tax Opinions

Salter v. Commissioner
T.C. Memo. 2022-29

On April 5, 2022, the Tax Court issued a Memorandum Opinion in the case of Salter v. Commissioner (T.C. Memo. 2022-29). The primary issues presented in Salter v. Commissioner were (i) whether the Code section providing exception from imposition of additional tax resulting from early distribution from retirement plan applied; and (ii) whether the taxpayer was entitled to itemized deductions when he failed to file a return, and the IRS filed a substitute for return on his behalf. Held: Nope on both counts, Shawn. Background to Salter v. Commissioner The IRS issued a notice of deficiency for 2013 to the petitioner after he failed to file a Federal income tax return for that year. He did not dispute the items of gross income shown in the notice of deficiency. However, he did dispute his entitlement to itemized deductions, the computation of an IRC § 72(t) additional tax for an early…

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November 23, 2022
Penalties Under the Code
Memorandum Opinions / Penalties Under the Code / Tax Opinions

Middleton v. Commissioner
T.C. Memo. 2022-28

On April 4, 2022, the Tax Court issued a Memorandum Opinion in the case of Middleton v. Commissioner (T.C. Memo. 2022-28). The primary issues presented in Middleton v. Commissioner were (i) whether the taxpayer could challenge the Trust Fund Recovery Penalty at his CDP hearing; and (ii) whether the taxpayer established that he was not “responsible person” for collecting, accounting for, and paying over employees’ income and employment taxes. Background to Middleton v. Commissioner In March 2007, Lineation Marketing Co. (Lineation) was organized and registered with the California secretary of state. Lineation provided roadway striping and signage. The petitioner was the responsible managing officer for Lineation during the relevant tax periods. Bank records show that the petitioner opened a checking account for Lineation in December 2012, and a savings account in September 2013. He was the only signer on the bank accounts. In November 2015, a revenue officer interviewed the…

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November 22, 2022