The Internal Revenue Service (IRS) says that tax audits have increased during the fiscal year ended Sept. 30, 2007. For example the IRS audited 84% more returns of individuals with income of over $1 million dollars than the previous year. This amounted to a tax audit rate of almost 10%.Tax…
Tax Problem Attorney Blog
United States Tax Court Amends Rules for Access to Tax Documents
Chief Judge of the United States Tax Court John Colvin announced the other day that the Tax Court has adopted amendments to the Tax Court’s Rules of Practice and Procedure. Most of these changes are effective as of March 1, 2008. However, the rules relating to remote access to electronic…
Trust Fund Recovery Penalty (TFRP) Deadlines Shortened by Internal Revenue Service (IRS)
The Internal Revenue Service (IRS) ( has reversed its previous lenient policy of allowing the IRS Appeals Division to consider untimely protests of the Trust Fund Recovery Penalty (TFRP). First, what is a trust fund recovery penalty? Actually, its not really a penalty. It’s simply a collection tool that the…
Tax Fraud Conviction Appeal Heard by Supreme Court
On January 8th the Supreme Court heard oral arguments in the criminal tax appeal of Michael Boulware. The case involved the return of capital theory in criminal tax evasion cases. To make a long story shorter, Boulware was convicted of tax evasion in violation of Internal Revenue Code § 7201.…
Internal Revenue Service (IRS) Payroll Taxes Collected from Sole Member of LLC
Small businesses which get behind on their debts also often fail to pay their payroll taxes resulting in payroll tax problems for the owners. Not paying payroll taxes is a big mistake since the Internal Revenue Service (IRS) can collect the trust fund portion of the payroll tax debt from…
Wrongful Levy Claim Instructions Provided by Internal Revenue Service (“IRS”)
The Internal Revenue Service (IRS) has provided new instructions for persons who wish to file wrongful levy claims against the IRS pursuant to Internal Revenue Code § 6343(b). These instructions are set forth in IRS Publication 4528 (Rev. Nov. 2007). If the IRS were to take your property to pay…
Internal Revenue Service (IRS) in Payroll Tax Dispute with FedEx
The Internal Revenue Service (IRS) is in a payroll tax dispute with FedEx, and the IRS is proposing to assess tax and penalties against FedEx because it believes that the company has improperly classified its drivers as independent contractors rather than employees. According to FedEx if the IRS prevails the…
Internal Revenue Service (IRS) Warns About Tax Preparer Fraud
The Internal Revenue Service (IRS) has issued FS 2008-10 warning taxpayers about tax fraud by tax preparers. The IRS points out that while most tax return preparers are honest a few are not, and that taxpayers need to be careful when choosing a tax return preparer. While it may seem…
Internal Revenue Service (“IRS”) Interest Rates Drops According to Notice 746
The Internal Revenue Service (“IRS”) has released Notice 746 which provides information about penalties and interest, and lists the latest interest rates. According to the notice interest rates will go down one percentage point in January. Not surprisingly the IRS generally pays 1% less on money it owes to taxpayers…
Internal Revenue Service (IRS) Extends Trust Fund Tax Express Installment Agreements Program
The Internal Revenue Service (IRS) has extended its policy of granting express installment agreements for in business trust fund taxes through at least June 6, 2008. See IRS Memo dated June 6, 2007 Express installment agreements are available to in-business taxpayers who have payroll tax problems of less than $10,000.…