US citizens, legal permanent residents, and other covered individuals have an obligation to file and pay taxes on all sources of worldwide income. If an individual does not satisfy his or her filing and payment obligations, he or she may be subject to penalties for a failure to pay taxes,…
Articles Posted in Tax Debt
Is there an accountant-client privilege? Why should I work with a tax attorney?
Conversations between a CPA and his or her clients may or may not be shielded from disclosure to third parties. Whether the accountant-client privilege exists is a fact-specific inquiry where the fact that your disclosures may not have been confidential may not emerge until it is already too late. This…
Tax Evasion Conviction of Las Vegas Attorney Paul Wommer Upheld by 9th Circuit Court of Appeals
Las Vegas criminal defense attorney Paul Wommer, was convicted of tax evasion based on his failure to pay approximately $13,000 of interest and penalties imposed on the principal of his delinquent taxes. In a somewhat novel appeal to the 9th Circuit he argued he hadn’t committed “tax evasion” under Internal…
Collection Due Process (CDP) Hearing Requests Sent to the Wrong IRS Office Creates Tax Problems
For the IRS to issue a Collection Due Process or CDP Notice. The CDP Notice is required by Internal Revenue Code Section 6330. The CDP notice is generally issued by the IRS on either Form LT-11 or Letter 1058, and it is titled “Notice of Intent to Levy and Right…
Important Offer in Compromise (OIC) Tip from a Senior IRS Collection Official
An Offer in Compromise (OIC) can be one of the best ways to avoid an IRS tax levy, and to reduce your tax debt if you have fallen far behind. Earlier this month I was speaking with a senior IRS collection official about Offers in Compromise, and he brought up…
California Franchise Tax Board (FTB) To Issue 475,000 Tax Levies for Delinquent Tax Debts
If you or your clients have tax problems and owe California State income taxes, the Tax Man Cometh! The California Franchise Tax Board (FTB) is collecting delinquent tax debts through the Financial Institution Record Match (FIRM) program. FIRM uses automated data exchanges to locate bank accounts held by Californians who…
Felony Criminal Tax Prosecution Goes Forward
United States v. Quinn (D. KS 2011) is one of several recent felony tax prosecutions, not for tax evasion, but for violation of Internal Revenue Code Section 7202. IRC Section 7202 makes it a felony to willfully fail to collect, account for, or pay over any tax due. In this…
Tax Attorney Blames OCD for Failure to File Business Income Taxes
Tax lawyers representing a man accused of failing to file business income tax returns told the judge that obsessive-compulsive disorder was responsible for their client’s tax problems, the Calgary Herald reported. Business tax debt can sink a business; frequent issues tax attorneys are called to deal with include payroll tax…
“Little Fockers” Star has Tax Liens for $433K in Back Taxes to IRS, State of California Franchise Tax Board
The Detroit News is reporting that Hollywood actress Teri Polo, perhaps best known for playing alongside Robert De Niro and Ben Stiller in “Meet the Parents,” has a tax lien for $433,736. The former Playboy pinup landed the role after a string of TV show appearances, including “The West Wing.”…
Wesley Snipes to Serve 3 Years for Failure to File Tax Returns
CNN reports Hollywood actor Wesley Snipes is off to serve a three-year prison sentence for failing to file tax returns. While simple non-filing of tax returns doesn’t often result in criminal tax fraud charges being brought, in some cases, it may require being proactive, and consulting an experienced tax lawyer…