A hard lesson for US taxpayer owners, settlors, or beneficiaries of foreign trusts was recently handed down in Emily S. Wilson et al. v. United States; No. 20-603. A U.S. citizen, by such relation to a foreign trust has the
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Hardship Factor in Innocent Spouse Cases
By Jason Morton
In part, below is an excerpt from the publication of Procedurally Taxing, published August 24, 2021, and it is very instructive concerning the importance of the Hardship factor in making Innocent Spouse claims.
Research of innocent spouse cases shows…
“Specificity” Very Important in Claim for Refund Requests
By Jason Morton
Three recent Federal Court cases, Premier Tech v. United States, No. 2:20-cv-890-TS-CMR (D. Utah 2021); Intermountain Electronics v. United States, No. 2:20-cv-00501-JNP (D. Utah 2021); and Harper v. United States, 847 F. Appx. 408 (9th Cir. 2021), remind taxpayers of…
Important IRS Development in the Property Characterization of All Cryptocurrency
By Jason Morton
I have written previously on this Blog and for Cointelegraph on the Jarrett v. Commissioner case filed on May 26 with a Tennessee Federal District Court (Case No. 3:21-cv-00419), whereby the taxpayers sought a refund of taxes they had paid…
The Nuts and Bolts of IRS Jeopardy Assessments for Tax Assessment Purposes
By Jason Morton
Jeopardy assessments for tax collection are rare, but they are a tool available to the IRS in extraordinary circumstances. Jeopardy assessments stand outside the normal IRS assessment procedures. In general,
and in extraordinary circumstances, jeopardy assessments permit the IRS to…
IRS Appeals is Changing and May Not Be for the Better
By Jason Morton
IRS Appeals Conferences may now include additional participants. After the conclusion of an IRS Appeals pilot program, the results suggest that IRS Appeals benefits from including examination teams and Chief Counsel attorneys to engage with taxpayers and their representatives at…
Timeliness of Tax Court Petitions for Innocent Spouse Claims
By Jason Morton
Normally, an Innocent Spouse Determination Letter denying relief is final unless a taxpayer files a Tax Court Petition to challenge the denial. If that Tax Court Petition deadline (90 days from the Innocent Spouse Determination Letter) is missed, then the…
Results of IRS Cryptocurrency Campaign
By Jason Morton
As a result of the IRS campaign against cryptocurrency tax noncompliance, it has received more than 1,000 amended tax returns, collected $13 million in taxes from crypto holders with more than $20,000 of transactions, and collected another $12 million from…
IRS Advancements in Cryptocurrency Tracking
By Jason Morton
The IRS is now using data analytics and article intelligence to access billions of crypto transactions in the digital world and make the process more efficient for IRS Criminal Investigators. Once your cryptocurrency becomes fiat currency and once it goes…
IRS Appeals and Your Rights
By Jason Morton
One often overlooked taxpayer right is his or her right to their full administrative case file prior to an IRS Appeals hearing. This is a legal requirement and is codified in IRC § 7803(e)(7). However, the taxpayer must affirmatively request…