By Hale Sheppard Life grants few chances at true redemption. The Internal Revenue Code, likewise, is not known for facilitating taxpayer salvation. Sure, under certain circumstances, taxpayers have an opportunity to file late tax-related elections to rectify an oversight, and other forms of clemency exist. However, the general rule is that taxpayers are stuck with [...]
Author Archive
The Parameters of Qualified Amended Returns Examined by Tax Court in Case of First Impression
March 9, 2012LLC Members and the Passive Activity Loss Rules: IRS Issues Proposed Regulations After Multiple Court Setbacks
February 29, 2012By Hale Sheppard Change is inevitable, particularly in the tax arena. The world evolves at such a quick pace that the IRS frequently finds itself playing catch up. Examples of this abound, but a recent event of interest involves the IRS’s attempt to deprive certain taxpayers of losses because of their decision to conduct business [...]
Settlement Program for Worker-Classification Issues: Putting the Latest Employment Tax Offer into Perspective
February 23, 2012By Hale Sheppard The difference between what taxpayers should pay and what they actually pay the IRS is called the “tax gap.” A significant portion of the tax gap is attributable to non-compliance with employment tax laws, including worker misclassification. The IRS is currently conducting a three-year research project, which entails an additional 6,000 random [...]
If You’re On Call, You’re Out of Luck in Passive Activity Cases
February 21, 2012By Hale Sheppard Back in the era of beepers, being “on call” evoked imagery of importance. Indeed, those people required by their job to carry a beeper, along with those who did so voluntary, displayed the devices with a noticeable degree of smugness. The positive aspects of this status symbol aside, anyone who has been [...]
Better Late than Never: IRS Radically Changes Aggregation Election Procedures in Passive Activity Cases
February 14, 2012By Hale Sheppard The tax code is best known for its strict rules, but it also features hundreds of taxpayer-favorable elections. The first step to evaluating and possibly taking advantage of these elections is being aware of their existence. Unfortunately, taxpayers and/or their advisors sometimes overlook an election or fail to follow the related procedures. [...]
Always Say Never: Does Financial Distress Create Reasonable Cause Sufficient To Abate Tax Penalties?
February 6, 2012By Hale Sheppard Nearly all taxpayers will face penalties by the IRS at some point, regardless of their sophistication level and size. Accordingly, tax practitioners, even those who claim not to get involved in traditional “collection” activities, must understand key aspects of abatement and collection procedures in order to effectively advise their clients. This is [...]
As the World Turns: Court Rebuffs Novel Spin on International Tax Filing Rules
March 25, 2011By Hale Sheppard For better or worse, many a tax dispute has been won or lost on procedure, often on the question of whether a document – be it a tax return, refund claim, or petition – was timely filed. The centrality of this issue helps explain the renown of the otherwise unremarkable “mailbox rule” (a.k.a. [...]
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Phil Karter
Jonathan Prokup
David Shakow
George Connelly, Jr.
Buck Buchanan
David Bernard
Dustin Covello
Heather Pesikoff
Hale Sheppard
dustincovello
