On February 17, 2009 President Obama signed into law the much publicized American Recovery and Reinvestment Act of 2009 (ARRA) which contained $787 billion worth of tax incentives and spending provisions intended to help revitalize the economy. The provisions...

On February 17, 2009, President Obama signed major new legislation known as the “stimulus bill” which provides $787 billion of tax incentives and spending provisions to improve the economy. To understand the tax implications for your clients,...

Introduction to the “Corporate Tax” and Resulting Double Taxation   A “corporation” is a legal entity created under a state or other statute that allows “incorporation” by persons who become the “shareholders”...

The irrevocable life insurance trust (ILIT) provides an accessible means of producing estate-tax-free dollars that is without equal in terms of the potential savings measured against what the grantor has to give up in return.   Basics of Life...

If your client can't stomach the tax bill received after an IRS audit, you may want to appeal to the IRS for a second look. So many taxpayers are able to downsize the amount of taxes, interest, and penalties owed by appealing that IRS agents grudgingly refer...

I. STANDING PRETRIAL ORDER   A. All Judges Now Use the Same Standing Pretrial Order.   1. The Court attaches the Standing Pretrial Order to the Notice Setting Case For Trial. 2. The Notice Setting Case For Trial is usually received...

Getting an audit notice can strike fear in the hearts of the bravest of taxpayers. Educating your client as to a few simple rules can make the process less painful for him or her.   Kinds of Audits   Audits differ in kind and may...

A partnership is often chosen over other structures as the tax entity best suited for the conduct of a business. Inevitably, taxpayers and their advisors must consider the disposition or monetization of their interest in that business. Extracting a taxpayer's...

Final Regulations under Circular 230, issued on December 20, 2004 (T.D. 9165) and as amended May 18, 2005 (T.D. 9201), establish standards for tax "practitioners" providing Covered Opinions and Other Written Advice as well as "best practices"...

Section 7430 (a) and (b) provide a taxpayer the right to recover costs, including fees of experts and attorneys paid or incurred:   1. In an administrative or court proceeding brought by or against the United States; 2. In which the taxpayer...

I. Choices of Business Entity.   A. Sole proprietorship. In conducting a business as a "sole proprietorship", an individual (the "sole proprietor") typically segregates a portion of his or her assets and dedicates...

A most important option available to a taxpayer is to appeal proposed audit adjustments to the IRS Appeals Office. Congress agrees and the IRS Restructuring and Reform Act of 1998, Pub. L. 105-206 (the "98 Act") required the Service reorganization...

The 2006 Federal Circuit Court of Appeals ruling in Coltec Industries, Inc. v. United States has given the Internal Revenue Service another weapon in its aggressive enforcement efforts against taxadvantaged transactions that are specifically structured...

On August 2, 2007, the Treasury Department and the IRS released a report titled “Reducing the Federal Tax Gap.” The report addresses the IRS’s strategy for reducing the tax gap. The report includes seven components and sets out compliance...

The Economic Growth and Tax Relief Reconciliation Act of 2001 introduced the Roth contribution program for 401(k) and 403(b) plans beginning in 2006, but with a limited duration set to expire at the end of 2010. The Pension Protection Act of 2006 eliminated...

Unfortunately, many citizens not familiar with Section 501(c)(3), are falling for a spam scam. The IRS is reporting that thieves are using a method called phishing, a technique used to acquire personal financial data in order to gain access to the financial...

Just starting out in the Tax Law field? A basic knowledge of the terms of art is key to impressing your client or managing partner with your ability to handle Tax Law matters competently. Read on for a quick primer!   Actions on Decisions...