Due to the exceptional economic downturn that the country has experienced, the number of struggling taxpayers who are unable to pay in full the taxes they owe has increased dramatically. One of the methods available to such distressed taxpayers is to enter into what is known as an Offer in Compromise (“OIC”) with the…
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Swiss Banks Shun Yanks
When Scott Schmith finally got his Swiss passport last month, it was time for him to take a drastic step: hand back his American one. Among the reasons was a pending U.S. regulation aimed at tracking down tax cheats that is making life difficult for some Americans abroad. These expatriates say that foreign banks, which have…
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IRS Collection Notices to Taxpayers in the OVDP program?
The IRS is sending out a slew of collection notices to taxpayers who paid 100% of all taxes, 100% of all interest, and 100% of all penalties. Why is this happening? If you owe money to the IRS, the first collection notice the IRS sends is known as a CP503. This letter is sent from…
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Denial of Whistleblower Award Not Subject to Review – U.S. Tax Court.
On an issue of first impression, the U.S. Tax Court held that the whistleblower statute does not provide relief to a taxpayer who has been denied an award where the Internal Revenue Service did not initiate an administrative or judicial action and collecting proceeding (Cohen v. Commissioner, T.C., No.26925-11W, 139 T.C. No. 12, 10/9/12). RaymondCohen…
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