August 21, 2015

How to release the wage levy?

The first question, the taxpayer needs to ask, is who issued the levy at the IRS? Was it the Automated Collection Service (ACS) or was it […]
February 4, 2015

Do later losses justify prior deductions?

It is a crime to knowingly overstate one’s deductions. I.R.C. Section 7201. The question posed here is whether one’s overstatement of his deductions somehow may be “justified” […]
July 28, 2014

Does IRC Section 269 Disallow a Net Operating Loss?

With the enactment of IRC Code Section 269, Congress sought to combat certain tax evading strategies involved with the acquisition of a corporation (or its assets). […]
July 28, 2014

At risk limitation and how it prevents claiming deductions

The at risk rules place limitations on a taxpayer’s ability to claim certain deductions. More exactly, deductions for losses stemming from a trade or business, or […]
March 26, 2014

What is The Stop Tax Haven Abuse Act?

We answer these and other questions below. a. Definition of “tax haven” There is no precise definition of what a “tax haven” is, but it typically […]
March 26, 2014

Possible for a Domestic Trust to Become a Foreign Trust?

In a word, “yes”—it is possible for a domestic trust inadvertently to become a foreign trust. This is significant because that means different tax rules apply, […]