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Tax Court Awards Partial Litigation Costs to Taxpayer’s Attorney

In a recent case before the United States Tax Court, the taxpayer asked the Court to award litigation fees to him because he prevailed in his case against the IRS. The IRS had previously denied the taxpayer’s dependency exemptions and…

November 21, 2016

Prior Tax Evasion Conviction Does Not Guarantee a Tax Deficiency Win for the IRS

In 2003, Bohdan Senyszyn misappropriated funds from a real estate developer in the amount of $252,726. Senyszyn subsequently pled guilty to criminal tax charges, including tax evasion, related to these funds. The IRS then audited Senyszyn’s tax return for 2003…

April 20, 2016

Tax Court Denies Request for Attorneys Fees

In a recent Tax Court case, a taxpayer’s request for attorneys fees was denied because the Court held that the IRS’ position that the taxpayer had unreported income was justified. The taxpayer late filed his tax returns for four years….

March 26, 2015

Should a Payment to Settle a Disability Insurance Lawsuit be Includible in Income?

The taxpayer was covered through his employer under a group long-term disability insurance policy. He did not pay any portion of the premiums and the value of the payments made by his employer for policy coverage were not included in his…

January 15, 2015

Taxpayer Cannot Challenge His Tax Liability in the Tax Court

Because the taxpayer had unpaid liability due to the IRS, the IRS issued the Final Notice of Intent To Levy seeking to collect the taxpayer’s unpaid liability for 2008 and 2009. In response, the taxpayer filed a Form 12153, Request…

December 04, 2014

Last Known Address On IRS File

Has the IRS issued a Notice of Deficiency in your name? Have you moved since you filed your tax return for last year? If yes, please read on. If the IRS disagrees with a position taken on your tax return…

July 24, 2014

notice-of-deficiency-90-days-to-file-a-petition

Notice of Deficiency – 90 Days to File a Petition

What do you do when you receive an IRS notice of deficiency in the mail? All IRS notices are very important and should never be ignored. Go to the post office to sign for the letters and bring them to…

November 27, 2013

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