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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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March 25, 2024

The ERC Voluntary Disclosure Window has Closed: Will It Reopen?... [ read ]

Last Friday, March 22, the IRS ERC Voluntary Disclosure program ended. So technically, there can be no more ERC Voluntary Disclosures. Interestingly the IRS announced that the program could potentially open at a later date.

March 20, 2024

The Clock is Ticking: IRS Identifies Seven (7) ERC Warning Signs in Advance of March 22nd deadline for IRS' Voluntary Disclosure Program... [ read ]

For those procrastinating, or just discerning, taxpayers that are still considering the IRS' disclosure program for employee retention credit (ERC) claims, the IRS released today seven potential red flags to help taxpayers make a decision before the program closes on March 22, 2024.

March 11, 2024

Deadline for ERC Voluntary Disclosure is Around the Corner... [ read ]

Blog readers are well aware of the IRS continuing enforcement efforts regarding the Employer Retention Credit (ERC). One tool in that enforcement effort is the ERC voluntary disclosure program for employers who received questionable ERC refunds. Introduced on December 22, 2024, the deadline for applying, March 22, 2024, is fast approaching. Any employer who has concerns about an ERC refund should consult with a competent tax advisor as soon as possible about whether they should be considering a voluntary disclosure.

February 29, 2024

IRS Launches New Effort at High Income Non-Filers: Impacted Taxpayers Should Seek Representation... [ read ]

On February 29, 2024, the IRS announced a new effort to target high-income individuals. This time the IRS announced that they have opened 125,000 cases focusing on millionaires who have failed to file income tax returns. The IRS believes that, based on third-party information received, there may be more than $100 billion of unreported financial activity and conservatively hundreds of millions of dollars of unpaid tax.

February 27, 2024

The Most Important Elements of a Successful IRS Voluntary Disclosure? Timing and Luck.... [ read ]

As in comedy, the most important element in an IRS voluntary disclosure is generally timing. However, a couple of U.S. Tax Court memorandum opinions in Whistleblower 14376-16W v. Commissioner, T.C. Memo 2017-181 and T.C. Memo 2024-22, point out that timing and luck are the most important elements of a voluntary disclosure

February 23, 2024

Another Shot Across the ERC Bow by the IRS... [ read ]

One of my ERC friends sent me the IRS letter below that was received by one of his ERC clients about their ERC filing. The letter, Notice CP271, says there has been aggressive advertising involving ERC and the employer should confirm they are entitled to the ERC amount they claimed.

February 21, 2024

Return Preparer Fraud Results in Harsh Outcome for Innocent Taxpayer... [ read ]

the IRS generally has three years to assess additional tax, pursuant to IRC Section 6501. The three years can be extended by agreement, the taxpayer filing for bankruptcy, the IRS issuing a Notice of Deficiency, or taxpayer involvement in a third party summons enforcement action.

February 21, 2024

IRS Announces New Audit Initiative Focused on Private Jet Usage... [ read ]

According to the IRS, private jet usage by certain taxpayers just doesn't fly. Today the IRS announced plans to initiate dozens of audits on business aircraft involving personal use. The audits will focus on aircraft usage by large corporations, large partnerships and high-income taxpayers and whether use of aircrafts is being properly allocated between business and personal reasons.

February 21, 2024

Can the U.S. Tax Court Hear ERC Lawsuits?... [ read ]

As more and more taxpayers consider filing lawsuits to receive an ERC refund, it is important to understand where the lawsuits can be filed. Before a taxpayer is legally allowed to file a refund lawsuit in court, taxpayers must first file a claim for refund with the IRS.

February 16, 2024

No Chocolate/Flowers: IRS Dishes Out the Threat of ERC Penalties as its Valentines Gift to Taxpayers... [ read ]

The IRS was not feeling the love this past Valentine's Day, releasing a new FAQ to its Employee Retention Credit Voluntary Disclosure Program that identifies the multitude of criminal and civil penalties that could apply to non-compliant taxpayers that choose not to participate in the program.

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