How Not To Respond To A Subpoena
The following is an article written by Gavin Broady for “Law 360” on February 6, 2015. It is a great article that provides keen insight into how not to respond to a subpoena from those who are most likely to take exception to a show of such defiance: none other than DOJ Chiefs themselves. The advice in this article is invaluable. “Law360, […]
Getting to Know The Structure of The IRS
The IRS is an agency of the Treasury Department and is charged with the administration of the tax laws. It is the largest government agency in the world. Headed by the Commissioner of Internal Revenue, its structure is as follows: (1) There are four civil compliance divisions responsible for serving specific groups of taxpayers with […]
SB/SE Issues Memo Outlining Changes to the Limitations Period for Cases Going to and Coming from IRS Appeals
This article was co-authored by Randall Brody, EA of Tax Samaritan. I wish to acknowledge his keen insight and invaluable contributions to this article. Picture this. You receive a notice of determination from the IRS informing you that you owe more tax than you reported on your tax return. As is usually the case, the IRS […]
Walking On Eggshells, Episode II: Attack Of The Fraud Examiners
When we last left our anthropomorphic friends, Rigby was in a serious coma due to an allergic reaction from the eggs in the Eggscelent omelet, and doctors were not optimistic about his chances. Meanwhile, Mordecai discovered a long-lost journal from a former park employee that may hold the key to winning the challenge and the […]
Harnessing The Power of Fear in Public Speaking – Tips & Tricks For An Unforgettable Presentation: Part II
When you hear the words “professional speaker,” do they conjure up a particular image in your mind? What exactly does a professional speaker look and sound like? What are some of the traits that successful speakers have in common? Before we delve into this, let me take you back to 1997. That was the year […]
Don’t Get Cracked!
In the Emmy award-winning “Regular Show” episode Eggscelent, Mordecai had to eat a 12-egg omelet in under an hour to win a funny-looking trucker hat for his good friend Rigby. Lawyers often face their own eggscelent challenge, but the stakes are quite a bit higher. My colleague Larry A. Campagna, who is a partner at […]
London Mayor Pushes Back Against the IRS For “Outrageous” Tax Assessment
London Mayor Boris Johnson is not taking the bait. He refuses to pay a tax assessment that the IRS claims he owes. The Mayor was born in New York and holds a U.S. passport as well as a British one. What brought this issue into the public spotlight? While visiting the U.S. last week to […]
Playing Russian Roulette with the IRS: Zwerner Learns The Cost of Hidden Offshore Accounts
Whether you have chosen to hide your account willingly or failed to file an FBAR by mistake, you may not know the full ramifications of your activities or your best course of action now. If you haven’t heard the horror stories yet, you’re about to have a couple to remember. For those who have kept […]
Making Sense of the FBAR Penalty Mitigation Guidelines: Four Easy Steps For Knocking The FBAR Calculation Out of the Park
This blog is intended for the taxpayer who plans on making a “quiet disclosure” of his unreported foreign financial assets and finds it necessary to estimate his FBAR liability in case of a doomsday scenario. By “doomsday scenario,” I’m referring to a situation where the IRS selects one or more years for examination, culminating in […]
From the IRS with Love – What to Do When Your Foreign Bank Writes to You about Reporting Your Account under FATCA
Nothing can ruin the taste of your martini, shaken not stirred of course, than a letter from your foreign bank demanding that you report the account that you hold with them to the U.S. government. For many, this can scare The Living Daylights out of them, especially since this probably has the IRS written all […]