Monthly Archives: October 2012

OVDP 2012 UPDATE

Posted on October 25, 2012 by taxpenaltylawyer

The third formal Offshore Voluntary Disclosure Program (OVDP 2012) was announced on January 9, 2012. The IRS finally got around to posting Frequently Asked Questions (FAQS) on its website on June 26, 2012.  The Tax Wars Blog post on August 6, … Continue reading →

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PUT IT IN THE MARITAL SETTLEMENT AGREEMENT

Posted on October 23, 2012 by taxpenaltylawyer

 In Luis Santana and Flor E. Vargas v. Commissioner, T.C. Memo 2012-49, the Tax Court upheld an IRS disallowance of a claimed dependency exemption for the tax year 2008 because the taxpayer Luis Santana (Luis) did not comply with the … Continue reading →

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FLANAGAN’S RESTAURANT OWNER WHO USED TWO SETS OF BOOKS TO UNDER-REPORT GROSS RECEIPTS WAS TRIPPED UP BY A FACT-SHEET USED TO BROKER SALE OF THE BUSINESS

Posted on October 14, 2012 by taxpenaltylawyer

 The dilemma faced by business owners who cheat on taxes: They don’t want to pay tax based on their true gross receipts but they want to be paid full price when they sell the business.  What to do? Flanagan’s Restaurants … Continue reading →

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IRS PR0POSED NEW RULES FOR DETERMINING IF SPOUSE QUALIFIES FOR EQUITABLE RELIEF UNDER IRC SECTION 6015(f)

Posted on October 4, 2012 by taxpenaltylawyer

INNOCENT SPOUSE MUCH LITIGATED One of the most litigated issues in Tax Court is an appeal from an IRS final determination that a spouse is not eligible for so-called “innocent spouse relief.”  “Innocent Spouse” is a phrase commonly used to refer … Continue reading →

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