By Phil Karter In a high profile summons enforcement case brought by the Internal Revenue Service against Coinbase, Inc. (United States v. Coinbase Inc., No. 3:17-cv-01431 (N.D. Cal. 2017)), a virtual currency exchange for traders of popular digital cryptocurrencies like Bitcoin, Ethereum and Litecoin, the Internal Revenue Service sought the production by Coinbase of all of its customer records … Continue reading Taxpayers With Unreported Cryptocurrency Gains Should Start Thinking About Filing Qualified Amended Returns – And Soon
By Phil Karter Any corporate tax executive who has ever been involved in contesting an audit adjustment knows all too well how unfavorable documents relating to the subject of the adjustment – particularly improvident comments reflected in email correspondences – can be an ongoing impediment to resolving a tax dispute from the audit phase right … Continue reading Cleaning Up After The Elephants – A Practical Reminder On Document Preservation Policies and Litigation Holds In Tax Disputes
As noted by Janet Novack at forbes.com, Judge England of the District Court for the Eastern District of California last week issued an order permitting the IRS to serve a "John Doe" summons on the California State Board of Equalization. The summons seeks the names of residents who transferred property to relatives for little or … Continue reading The IRS Can Summons California For Property Transfer Records
By Phil Karter In a recent TaxBlawg post, my colleague Jonathan Prokup discussed the IRS’ intention to begin requesting electronic files as part of taxpayer examinations so that it can analyze the “metadata” contained in those files. One of the concerns raised in the post, as announced in Chief Counsel Advice 201146017, was the possibility that … Continue reading IRS Records Retention Requirements In The Age Of Metadata
By Phil Karter As reported earlier this week in the tax press, the recently completed initial filing season for Schedule UTP produced at least one major surprise in the eyes of IRS officials, who had anticipated a much greater number of items listed on the average Schedule UTP than actually materialized. In fact, the IRS’s … Continue reading Musings in the Aftermath of the First Schedule UTP Filing Season
By Jonathan Prokup In the last two weeks, various news sources have reported on a previously low-profile IRS initiative to use state land-transfer records to identify potential omissions in reporting gifts of real estate. (Via TaxProf here and the WSJ here.) According to the reports, the IRS is using information received from at least 16 … Continue reading Using Non-Tax Sources To Fight Tax Battles: Are You Exposed?
The IRS National Employment Tax Research Project has started. On November 9, 2009 the IRS announced its first employment tax research project in 25 years. Under the program, which will last from 2010 through 2012, the IRS will audit 6,000 employers randomly selected from all employment tax filers. It is our understanding that the initial … Continue reading Tax Blawg Report on IRS National Employment Tax Research Project