Almost unnoticed, Congress is close to approving a law under which the Internal Revenue Service (IRS) will be able to revoke the passports of Americans who owe substantial unpaid taxes. It would allow federal officials to revoke or deny passports to delinquent taxpayers who owe the Internal Revenue Service $50,000 or more. The provision passed…
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Fast Track Settlement – A Process for Prompt Resolution of Large Business and International Tax Issues
IRS has recently released Publication 4539, which provides taxpayers with an overview of the Fast Track Settlement (FTS) process. The pub includes information on who can use FTS, advantages to its use, and how a taxpayer can start the FTS process. Corporate taxpayers under examination by IRS's Large Business and International Division (LB&I) can get…
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Second Circuit Court of Appeals Reverses Stockbroker's Tax Evasion Conviction
The U.S. Court of Appeals for the Second Circuit reversed a New York stockbroker's conviction April 30 on charges of tax evasion for 1996 and 1997 due to insufficient evidence, and vacated her convictions for mail fraud and tax evasion for 1995 on the grounds the counts were improperly joined (UnitedStates v. Litwok, 2d Cir.,…
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Partnership dissolution before death caused assets to be included in estate at full value
Estate of Lois L. Lockett, TC Memo 2012-123 The Tax Court has found that a family limited partnership terminated under state law when one partner, an individual, became the entity's sole owner. As a result, the individual owned 100% of the former entity's assets at her death and they were taxable in her estate at…
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