A recent advisory issued by the Chief Counsel's Office of the Internal Revenue Service ("IRS") sets forth the IRS's position on the procedures that its agents must follow in order to obtain a taxpayer's e-mails from his or her Internet service provider ("ISP"). In I.R.S. Chief Counsel Advisory("I.R.S. C.C.A.") 2011-41-017 (July 8, 2011), the IRS…
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What Type & Form of Disclosure is Necessary to Avoid Penalties?
Revenue Procedure 2012-15 updates Rev. Proc. 2011-13, 2011-3 I.R.B. 318 and identifies circumstances under which the disclosure on a taxpayer’s income tax return with respect to an item or a position is adequate for the purpose of reducing the understatement of income tax under section 6662(d) of the Internal Revenue Code and the purpose of…
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Supreme Court Denies Review of Sixth Circuit's Decision that Property Held as Tenants By the Entirety is Subject to Forced Sale!
The U.S. Supreme Court denied review on Jan. 17 of the court of appeals ruling that a Michigan woman who did not owe unpaid taxes to the United States but owned a home with her tax delinquent husband as tenants by the entirety could not prevent the government from selling the property in a tax lien foreclosure (Barczyk…
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Florida Poised to Pass an Internet Sales Tax?
According to an estimate by the National Conference of State Legislatures, Florida is projected to lose more than $1.4 billion in revenue in 2012 due to the online sales tax loophole. Florida policymakers are considering an “e-tax” law. If any of the pending online sales tax bills make their way through the redistricting-focused legislative session…
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