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Articles

How to Settle Your IRS Tax Debt in Florida

Settle IRS Tax Debt Florida

When you owe a substantial and accruing amount of tax debt to the Internal Revenue Service, it can feel absolutely crushing. The prospect of going up against a large federal agency, particularly the IRS, will stress and intimidate most of us. In such cases, it is important that you don't try to do it all on your own, and seek the counsel and guidance of an experienced Florida tax lawyer. read more

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Offer In Compromise: Alternative to Collection

By: Mary Lundstedt, Esq., Associate and Rebecca Sheppard, Esq., Associate  

Have you ever considered filing an offer in compromise with the IRS to "settle your debt for pennies on the dollar"? Until recently, filing an offer in compromise was believed to create an automatic hold on collection action--i.e., the IRS would not be able to levy your property once it was filed. However, an Eighth Circuit Court of Appeals clarifies that an offer in compromise will not prevent a court from granting the IRS’s request to levy on a personal residence. read more

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Untimely CDP Arguments Worth Consideration

By Eli S. Noff, Esq., CPA, Partner

Mary Lundstedt, Esq.

The taxpayer in Berkun v. Commissioner1 ultimately raised two collection due process arguments too late for consideration on appeal, but the Eleventh Circuit apparently found them worthy enough to highlight in a published opinion. Although the Eleventh Circuit uses a popular Seinfeld reference to describe its own non-substantive ruling in Berkun as potentially appearing to be an opinion "about nothing,"2 the opinion puts practitioners on notice of two arguments that could actually be something when properly raised. read more

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Coming Out of the Dark of International Tax Avoidance

By: Eli S. Noff, Partner and Peter Palsen

Jakarta, Indonesia - 1990

The aroma of my strong Java coffee blended with the smell of the dark teak paneling of the conference room of my client's office. I glanced at my U.S.-citizen client and then back to the two bankers who had travelled to Indonesia to promote an investment in an offshore fund. Before the meeting, I had made my client aware that the U.S. Congress had only a few years earlier enacted a punitive rule to discourage U.S. tax residents from making such investments. read more

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How Do You Challenge a Florida Tax Audit?

The tax audit process in Florida can be a harrowing one. Often times, after the audit is done, you just pay what you owe and move on. But there are times when you might not be satisfied with the results of the tax audit. The tax auditor may be pressurizing you to pay right away and you may be struggling because you either believe you don't owe money or you may not be able to afford to pay off the tax debt. read more

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Be Vigilant When Hiring A Tax Preparer: Two Tax Preparers in Maryland Guilty of Filing False Returns

By Glen Frost, Managing Partner and Mary Lundstedt, Esq., Associate The Comptroller’s Field Enforcement Division and the Criminal Investigations Division of the Maryland Attorney General’s Office, working in tandem, investigated and prosecuted two more Maryland tax preparers—resulting in guilty pleas. On July 24, 2018, Maryland Attorney General Brian E. Frosh and Comptroller Peter Franchot announced that two tax preparers operating in the Baltimore area pleaded guilty to filing false tax returns.Both Maryland officials report that, Michael Anegbode, pleaded guilty to three counts of filing false income tax returns. Anegbode was sentenced to three years’ probation and ordered to pay restitution in the amount of $48,808. Uwagbale Oigbokie pleaded guilty to two counts of filing false tax returns. He faces two years’ probation and must pay $81,712 in restitution.According to officials, these preparers cheated on two levels. First, they prepared returns for their clients which included false information in order to minimize their clients’ tax liability and increase their refunds. Next, the preparers filed false personal income tax returns for themselves—omitting fees which they earned by preparing and filing their clients’ false returns. Attorney General Frosh, stated:"They cheated twice. They falsely understated the taxes owed by their clients, and then they did not report the fees that they earned themselves."In recent years, the Comptroller’s office has increased its efforts to combat tax fraud. Maryland’s Taxpayer Protection Act of 2017 expanded the role of the Comptroller’s Field Enforcement Bureau by adding admissions and amusement tax, income tax, and sales and use tax to the list of laws within enforcement agents’ jurisdiction. Furthermore, the Comptroller now regularly publishes and updates lists—on its publicly accessible website—of suspended tax preparers. Listed tax preparers are suspended from their return filing privileges upon the Comptroller’s finding that it has received a "high volume of questionable returns" from the preparers. In February of 2018, Comptroller Franchot stated:"My top-notch Questionable Return Detection Team is vigilant in rooting out returns that try to cheat the state and steal money from hardworking Marylanders."

Along with the announcement of the two guilty pleas, the Comptroller gives every indication that its efforts will remain strong. Franchot emphasized that, "[o]ur Field Enforcement officers will continue to vigilantly investigate those who try to cheat our state and I want to thank the Attorney General’s Office for its partnership and its efforts prosecuting these cases." read more

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The Foreign Account and Tax Compliance Act: What is FATCA?

By: Eli S. Noff, Esq., CPA, Partner
Mary Lundstedt, Esq., Associate 
Brent Conrad read more

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What's Your Alien Tax Status and How Does It Affect Investment Property?

By: Eli S. Noff, Esq., CPA, Partner
Mary Lundstedt, Esq., Associate
Brent Conrad read more

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IRS Actively Targeting Taxpayers for Passport Denial/Revocation - Notice CP508C

By: Eli S. Noff, Esq., CPA, Partner & Mary Lundstedt, Esq., Associate read more

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United States V. Garrity: Clarifies Standard of Proof and Establishing Willfulness in FBAR Context

By: Eli Noff, Partner and Mary Lundstedt

On April 3, 2018, in United States v. Garrity, the U.S. District Court for the District of Connecticut considered the Government's suit to reduce to judgment a willful Report of Foreign Bank and Financial Accounts (FBAR) penalty and determined that: (1) the burden of proof is preponderance of evidence, and (2) proof of reckless conduct is sufficient to establish willfulness.1 Now, even the standard of proof required for civil tax fraud is higher than that required for proving a willful FBAR violation. read more

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