S Corporations & the NonFiler

A very common situation for a non-filer is an S corporation that has not filed in a number of years. To activate the corporation and put it in good standing can involve substantial fees. First, a taxpayer will have to pay substantial franchise tax fees and penalties for failing to file state income ...
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How To Settle Your Taxes

When it comes to tax collection, the IRS isn’t the only government agency that you need to worry about. The Department of Justice can be involved in getting court judgments on tax payers and collecting back taxes. Generally, the tax situation has to be pretty serious for the Department of Just...
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The IRS Restructuring and Reform Act of 1998

In 1997, Congress held extensive hearings about IRS abuse. During those hearings, there was testimony about taxpayers literally committing suicide because of the harassment they say they were receiving from IRS collection agents.  In response to public outrage, Congress enacted The IRS Restructuri...
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The Administrative Summons

A person represented by counsel may be required to attend an interview if summoned to do so. An Administrative Summons is issued under authority of IRC section 7602. Thus, even a taxpayer who is represented by a Power of Attorney, may nevertheless, be summoned to appear to give testimony regarding t...
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The IRS and Your Right to Representation

The Internal Revenue Code makes it clear that any time you are dealing with the IRS, you have the right to representation in connection with contact with any employee or officer of the IRS. IRC 7521(b)( 2)provides as follows: “If the taxpayer clearly states to an officer or employee of the Interna...
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Your Rights To Appeal Findings in an Audit

At the conclusion of an audit, a Revenue Agent or Tax Compliance Officer will write up their report with a Notice of Deficiency Waiver. Once you sign this form, you are allowing the IRS to assess and collect the tax. A Taxpayer should never sign this form if they disagrees with the amount the IRS ...
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What if the IRS requests a meeting with you?

If the IRS requests a meeting with a Taxpayer, should the taxpayer and a representative attend? Should only the representative attend? Should neither attend? Under no circumstances should a taxpayer attend on his or own. Rarely should a taxpayer attend with a Representative – the goal is to keep t...
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FBAR in a FATCA World

FBAR is an acronym standing for Report of Foreign Bank and Financial Reports. This report is due annually June 30th on all Taxpayers with offshore assets; it is a Report that Taxpayers must file in addition to disclosure on schedule B of their 1040s. There are extremely harsh penalties of up to 50 p...
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Breaking California Residency

Everyone is leaving California; few are migrating here. U-Haul charges four times as much for outbound trucks and trailers as in-bound. The state has been run into the ground by a tax and regulatory climate that is the worst in America. Breaking California residency is tough. Just getting a driver...
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