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Monthly Archives: May 2019

LB&I Announces Large Corporate Compliance Program

The Internal Revenue Service announced on May 16, 2019 a key advancement in how it identifies its biggest and most complex large corporations. The IRS's Large Business and International Division (LB&I) began a new application of data analytics for determining the population of its largest and most complex corporate taxpayers. This new Large Corporate Compliance (LCC)…
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Bowling Alley Heirs Get Balled Over and Owe $1.3M In Taxes.

According to Law360, a deceased Tennessee man’s estate was liable for $1.3 million in taxes owed by his defunct bowling company since asset transfers to another company were fraudulent, the Sixth Circuit said in a Wednesday affirmation of a U.S. Tax Court decision. Billy F. Hawk Jr.'s estate is liable for the taxes because Holiday…
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Tax Gap Hearings in House NOT Likely to Result in Passable Legislation

On May 9, 2019, the House Ways & Means Committee held a hearing about the "tax gap" — the difference between the amount of taxes owed and those paid on time. The IRS needs more revenue officers and resources.  “The most recent Internal Revenue Service estimate of the annual gross tax gap is about $460 billion…
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Beneficiaries Were Liable for Estate's Unpaid Tax Liability

A district court found that beneficiaries were liable for an estate's unpaid tax liability under Code Sec. 6324(a)(2). The undisputed facts showed the estate's federal estate tax was not paid when due and each beneficiary received property includible in the gross estate. (U.S. v. Ringling, (DC SD 2/21/2019) 123 AFTR 2d ¶2019-448)   If an…
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