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Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P.

901 Main Street, Suite 3700
Dallas, TX 75202

Phone: (214) 744-3700
Fax: (214) 747-3732
Toll Free: (800) 451-0093

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May 4, 2017

IRS Scores a Tax Court Win in its All-or-Nothing Approach to the Self-Employment Taxation of Limited Partners... [ read ]

Last year IRS Chief Counsel declared that a "partnership is not a corporation" and that the "wage and reasonable compensation rules which are applicable to corporations…do not apply." Therefore once a partner is no longer a "passive investor," his or her entire distributive share of partnership income is subject to self-employment tax. IRS Chief Counsel Advice 201640014

April 19, 2017

An Issue for Real Estate Developers and Their Tax Advisors to Keep An Eye On... [ read ]

On April 10, 2017, the IRS Chief Counsel's Office issued an Action on Decision (AOD 2017-3) refusing to acquiesce to the Tax Court's and 9th Circuit's decisions in Shea Homes Inc. v. Commissioner, 834 F.3d 1061 (9th Cir. 2016), aff'g 142 T.C. 60 (2014). Because of the potential tax benefits associated with the Shea Homes decision, real estate developers and their tax advisors should keep an eye on any future developments.

April 6, 2017

The Government Settlement Transparency & Reform Act (S.803): Are the Tax Benefits of Corporate Settlements in Jeopardy?... [ read ]

On April 3, 2017, Senators Jack Reed (D-RI) and Chuck Grassley (R-Iowa) introduced bipartisan legislation that may impact or deny tax deductions for settlement payments regarding corporate regulatory violations. In recent years, the federal government has increased enforcement efforts against corporations for regulatory violations, whether it be for healthcare, banking, or environmental violations. Although the federal government carries a big stick when it comes to regulatory enforcement (i.e. onerous civil fines and potential criminal penalties), there are also carrots that can often facilitate and expedite settlements with corporations.

April 5, 2017

TIGTA Report: The IRS Putting Innocent Small Business Owners at Risk in Currency Structuring Seizures and Forfeitures... [ read ]

On March 30th, the Treasury Inspector General for Tax Administration (TIGTA) released a report titled "Criminal Investigation Enforced Structuring Laws Primarily Against Legal Source Funds and Compromised the Rights of Some Individuals and Businesses." The TIGTA report (the Report) analyzed and made recommendations regarding how IRS Criminal Investigation (CI) administered cases involving possible currency structuring violations of Title 31 U.S.C. Section 5324(a).

March 30, 2017

Second Circuit Decision in Chai v. Commissioner Says No Penalties When the IRS Failed to Obtain Written Approval... [ read ]

On March 20th the U.S. Court of Appeals for the Second Circuit issued an opinion in Chai v. Commissioner that could impact every taxpayer who is disputing IRS penalties. Taxpayers with penalty cases pending in Tax Court should review the Chai decision as soon as possible and determine its application to their case.

March 27, 2017

TIGTA Recommends That The IRS Pursue More Criminal Employment Tax Cases... [ read ]

On March 21, 2017, the Treasury Inspector General for Tax Administration (TIGTA) issued a report entitled "A More Focused Strategy is Needed to Effectively Address Egregious Employment Tax Crimes". The report presents the results of TIGTA's evaluation of the IRS civil and criminal enforcement actions regarding payroll tax noncompliance. The report calls employment tax noncompliance a "serious crime" and recommends that the IRS, including Criminal Investigation (CI), "consider a focused strategy to enhance the effectiveness of the IRS's efforts to address egregious employment tax cases". "Egregious employment tax cases" are defined as employers who have 20 or more quarters of delinquent employment taxes. The number of employers with egregious employment tax noncompliance has more than tripled in recent years. As of December 2015, 1.4 million employers owed approximately $45.6 billion in unpaid employment taxes, interest and penalties.

March 22, 2107

New IRS Guidance Outlines the Procedures that Apply When a Taxpayer "Whistle Blows" on their Return Preparer... [ read ]

The IRS Small Business/Self-Employed Division issued a memorandum to all examination and collection personnel setting forth procedures that apply when a taxpayer alleges return preparer misconduct. The memorandum narrates a cautionary tale for unscrupulous preparers and serves as an important reminder to conscientious preparers to better communicate with clients so as to avoid misunderstandings.

March 15, 2017

Address IRS Tax Debts Now, Before a Passport is Revoked... [ read ]

Section 7345 entitled "Revocation or denial of passport in case of certain tax delinquencies" was added to the Internal Revenue Code in late 2015. The IRS has announced that it will begin sending tax debt certifications to the State Department in early 2017 for revocation or denial of passports. Denying or revoking a person's freedom to travel can have devastating effects including disrupting business, impeding or eliminating an individual's ability to generate income and potentially separating families. Therefore, it is imperative that any person with an IRS tax debt who regularly travels internationally or plans to do so, understand when they may become subject to Section 7345, what type of debts can be excluded from Section 7345 and their options if they receive notice of a tax debt certification.

March 13, 2017

Divorce Final? Not So Fast.... [ read ]

After navigating the turbulent waters of a divorce, many clients have had enough of lawyers and accountants to last a lifetime. Nevertheless, there are many legal and financial matters that should be attended to in order to protect you and your family from unintended consequences, or frankly, an outright mutiny among your family in the event of your death or incapacity.

March 1, 2017

Federal District Court Holds that Taxpayer Showed Reasonable Cause for Abatement of Late-Filing Penalties in Relying on a Tax Professional... [ read ]

For a multitude of reasons, the late-filing penalty has remained a priority of the IRS. First, the late-filing penalty is easy for the IRS to police through the use of modern computer systems which automatically identity and impose the penalty after a return has been filed late. Second, the amount of the penalty, or 25% of the net tax due after only five months, represents an easy windfall of revenue to the Government. Third, imposition of the late-filing penalty naturally deters taxpayers from filing their returns late and promotes compliance with the tax system. Fourth, attempts by taxpayers to have the penalty waived or abated—termed "reasonable cause" in tax parlance—require an affirmative showing of relief upon which the taxpayer bears the burden of proof.

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