by Tom Regan | Sep 10, 2022 | Audit
When it is too late to file a corrected tax return and you think the IRS or MDR assessment is wrong, you may still be able to challenge the assessment without going to court. For the IRS, the procedure is known as an Audit Reconsideration Request (AR). The IRS has the...
by Tom Regan | Mar 14, 2017 | Audit
I am often asked how long do I have to maintain records to protect myself against actions by the Internal Revenue Service? Along with that question comes the question about whether the IRS has the burden of proving a taxpayer owes the tax (assuming it met its burden...
by Tom Regan | Apr 30, 2014 | Audit
The United States Supreme Court is considering an investor’s objection to summonses issued by the IRS. United States v. Clarke, No. 13-301. Mr. Clarke, the investor, is arguing the IRS improperly issued summonses as retribution against him and his business...
by Tom Regan | Apr 9, 2014 | Audit
Settlements in legal disputes between employers and employees can vary significantly depending on whether the amounts to be received are taxable. For example, two parties in separate lawsuits can each agree to a settlement of $500,000. But, because one settlement is...
by Tom Regan | Jan 3, 2013 | Audit
There are many tax and social benefits to gifting a conservation easement. Unfortunately, some taxpayers are in too much of a hurry to make the contribution and do not complete all of the steps necessary to receive all of the tax benefits. The U. S. Tax Court,...
by Tom Regan | Dec 27, 2012 | Audit
Doing well in a full time job is hard enough, but some people, for many reasons, spend significant time, energy, and money away from their “regular job” trying to build themselves a better future through real estate. They often feel like they spend every waking hour...
by Tom Regan | Nov 6, 2012 | Audit
I have been watching the tax cases dealing with building facade easements for insight into how the IRS and the courts are reacting to the significant deductions being taken by partners in real estate partnerships. These partnerships generally buy a building, develop...
by Tom Regan | Sep 4, 2012 | Audit
Many individuals and businesses fail to file their income tax returns for multiple years for a variety of reasons, usually stemming from life and business pressures that made it almost impossible for them to file their returns. When they finally have the time and...
by Tom Regan | Dec 22, 2011 | Audit
In Scharf v. Comm’r 32 T.C. Memo 1247 (1973) acq, in result, 1974 WL 36031, the United States Tax Court decided, and the IRS had acquiesced to the decision, that a charitable contribution deduction was available for the donation of a building (albeit partially...
by Tom Regan | Dec 15, 2011 | Audit
In the early 1980s, there was an almost endless supply of tax shelters promising deductions and credits that produced benefits far in excess of the investor’s contribution. These shelters were not just for wealthy, promoters pushed them on the average income...
