Taxing, Briefly
Taxing, Briefly

Statutes of Limitation on Assessment and Collection

One of the most common questions I am asked by taxpayers is “How long can the IRS try to collect my liability?” It’s a good question, and one that would seem to have a quick, easy answer. Judging purely by the length of this article, however, the answer is never as simple as it might seem. On Statutes of Limitation on Assessment and Collection With the full understanding that “It depends” is the least satisfying

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Taxing, Briefly
Taxing, Briefly

Can the Government Take My Tax Refund?

A maxim for today: The Government giveth, but more often it taketh away. Within the last two weeks, I have been approached and asked by multiple folks, “Can the government take my tax refund?” In this Taxing, Briefly article, we’ll discuss offsetting tax refunds to pay other state and Federal obligations. If you overpay tax to the government (due to over withholding or some other fortuitous circumstance), you are entitled to a refund of this overpayment.

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Taxing, Briefly
Taxing, Briefly

Donation-Based Crowdfunding

Background to Donation-Based Crowdfunding You’ve seen it on Facebook countless times. A tragedy occurs to a friend of a friend, and your (first level) friend sets up a GoFundMe page to raise money for the poor unfortunate souls. An old friend approached me not too long ago. Her brother needed an organ transplant, but because he majored in circus at Florida State (no joke…well, a circus major is, itself, a joke), her brother had no

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Taxing, Briefly
Taxing, Briefly

Moving Beyond the Basics of Charitable Contributions

In our previous post, we took a high level look at charitable contributions and deductions, including looking at what made an organization “qualified” to receive charitable contributions, when deductions might be limited, and special rules for valuing and reporting non-cash charitable contributions. In this post, “Beyond the Basics of Charitable Contributions,” we will dig a little bit deeper and look at some issues that might affect the deductibility of a contribution. Moving Beyond the Basics

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Taxing, Briefly
Taxing, Briefly

Basic Concepts for Charitable Deductions

Your grandmother Phyllis was a remarkable woman. Aside from making it out on the other side of Uncle Bill’s childhood with only moderate shell shock (which, I suppose, is referred to these days as PTSD), Phyllis was an intelligence agent in the United States Army towards the end of World War II, and you could remember her saying that, despite as “intelligent” as she may have been in the Army’s estimation, her good genes weren’t

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Taxing, Briefly
Taxing, Briefly

Taxing, Briefly – Can the IRS Take My Passport?

When my son was two, his grandmother gave him a stuffed owl. Not a particularly creative toddler, he named the little owl Stuffy, and the name has stuck to this day.  What does this have to do with the question “Can the IRS Take My Passport?”  Patience…all will be revealed. He took the owl everywhere, which naturally led to many a calamity when Stuffy was inevitably misplaced. For my wife and I, Stuffy also had an

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Taxing, Briefly
Taxing, Briefly

Taxing, Briefly: Will the IRS Take My House?

I met a new client about a month ago.  I was excited. It was the first in-person meeting I’d had for over a year due to COVID.  The client had settled a lawsuit, and the settlement income—though taxable—had been reported incorrectly on her Form 1099-MISC, so that the IRS got it into its administrative head that it was subject to self-employment income. It wasn’t. The client’s total liability would have been about $10,000, which was

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Hamilton v. Commissioner
T.C. Memo. 2022-21

On March 15, 2022, the Tax Court issued a Memorandum Opinion in the case of Hamilton v. Commissioner (T.C. Memo. 2022-21). The primary issues presented in Hamilton v. Commissioner were (1) whether the Tax Court would consider taxpayers’ testimony and documentary evidence; (2) whether the notices of determination contained plain

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Bunton v. Commissioner
T.C. Memo. 2022-20

On March 10, 2022, the Tax Court issued a Memorandum Opinion in the case of Bunton v. Commissioner (T.C. Memo. 2022-20). The primary issues presented in Bunton v. Commissioner were (1) whether Brian and Karen were entitled to challenge the existence and amounts of their underlying tax liabilities for the

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DelPonte v. Commissioner
158 T.C. No. 7

On May 5, 2022, the Tax Court issued the full opinion in DelPonte v. Commissioner (158 T.C. No. 7). The primary issue presented in DelPonte v. Commissioner was whether the IRS’s Cincinnati Centralized Innocent Spouse Operation (CCISO) or the IRS’s Office of Chief Counsel has the final authority to determine

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Treece Financial Services Group v. Commissioner
158 T.C. No. 6

On April 19, 2022, the Tax Court issued the full opinion in Treece Financial Services Group v. Commissioner (158 T.C. No. 6). The primary issue presented in Treece Financial Services Group v. Commissioner was whether the Tax Court had jurisdiction to determine whether Voluntary Classification Settlement Program (VCSP) entered into

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BATS Global Markets Holdings Inc. v. Commissioner
158 T.C. No. 5

On March 31, 2022, the Tax Court issued the full opinion in BATS Global Markets Holdings Inc. v. Commissioner (158 T.C. No. 5). The primary issue presented in BATS Global Markets Holdings Inc. v. Commissioner was whether the petitioner’s transaction fees, routing fees, and logical port fees qualify as domestic

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Aptargroup Inc. v. Commissioner
158 T.C. No. 4

On March 16, 2022, the Tax Court issued the full opinion in Aptargroup Inc. v. Commissioner (158 T.C. No. 4). The primary issue presented in Aptargroup Inc. v. Commissioner was whether the taxpayer was required to characterize stock in controlled foreign corporation using gross income method. Held: Yes, indeed it

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