Denver Tax Blog

IRS Reminds Nonresidents, Owners Of Foreign Assets, And Others Of Looming Deadlines

IR-2013-54 The IRS has issued a reminder to taxpayers with a variety of foreign-related connections about upcoming filing obligations. Citizens and resident aliens living abroad may have to file by June 17, 2013, for...

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Deadline Extended for Preparers’ Use of New Taxpayer Consent Language

The IRS has announced a one-year extension of the deadline for tax return preparers to use new language on a taxpayer’s consent to disclose and use return information for returns in the Form 1040...

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Simplified Home Office Deduction

The IRS has announced a new simplified, optional method of claiming a home office deduction (Rev. Proc. 2013-13; IR- 2013-5). Over three million taxpayers claimed deductions for business use of a home in 2010, which...

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Litigation Expenses for Acquisition of Capital Assets must be Capitalized

Litigation expenses incurred by a company in resolving claims arising from a merger and acquisition were capital expenses and, therefore, not deductible as ordinary and necessary business expenses. Some of the company’s shareholders challenged...

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Offer In Compromise based on Effective Tax Administration

Taxpayers can submit an Offer in Compromise (OIC) to the IRS based on the need to promote Effective Tax Administration (ETA).  This ground for an OIC exists if collection of the tax liability would...

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Appealing Unfavorable Determinations by the IRS

When an IRS Service Center or Area Office makes a determination that the taxpayer disagrees with a tax controversy arises.  Most determinations can be appealed.  The most common determinations appealed are: Collection Actions, such...

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First-Time Homebuyer Credit Denied For Residence Purchased Through S Corp

An individual cannot claim the Code Sec. 36 first-time homebuyer credit for a principal residence purchased through an S corporation.   A husband and wife were the sole shareholders of an S corporation that...

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Claims and Suits for Refund

Taxpayers must file a proper and timely claim for refund with the IRS before they can file suit to recover an overpayment of tax in the Court of Federal Claims or U.S. District Court....

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Notice of Federal Tax Lien Held Invalid for Lack of Specificity

In Conway v. Commissioner, 137 TC No. 16 (Dec. 19, 2011), the Tax Court upheld a proposed levy against one taxpayer for Trust Fund Recovery Penalties (TFRPs), but overturned a notice of federal tax lien...

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Substantive Challenge to the S.O.L. on Assessments is no Defense to a Summons

Asserting a defense that an assessment would be untimely does not rebut the Government’s showing of a legitimate purpose in seeking information for the purpose of determining a tax liability. Facts:  The Internal Revenue Service...

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