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United States Tax Court has adopted final amendments to its Rules of Practice and Procedure, including new Title XXIV (Partnership Actions Under BBA Section 1101)

Chief Judge Maurice B. Foley announced today that the United States Tax Court has adopted final amendments to its Rules of Practice and Procedure, including new Title XXIV.A (Partnership Actions Under BBA Section 1101), and certain conforming and miscellaneous amendments. The Court has also adopted revisions to Form 1 (Petition), Form 7 (Entry of Appearance),...
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Can I submit an Offer in Compromise through a CDP Hearing?

You may appeal many IRS collection actions to the IRS Independent Office of Appeals (Appeals). Appeals is separate from and independent of the IRS Collection office that initiated the collection action. Appeals ensures and protects its independence by adhering to a strict policy of prohibiting certain ex parte communications with the IRS Collection office or...
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How Does the CDTFA Audit Bundled Cell Phone Sales?

People often ask their tax lawyer how to respond to the CDTFA when they receive an audit letter. A CDTFA audit can present may issues for the taxpayer to consider and address. One issue that comes up in a CDTFA audit is what is called a bundled sale. The CDTFA began focusing its audit efforts...
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What Should I do If I Receive an IRS Summons?

Taxpayers frequently ask their tax attorney what they need to do if they receive an IRS summons. Internal Revenue Code (IRC) § 7602 provides the Internal Revenue Service with summons authority. IRC § 7601 authorizes the IRS to inquire about any person or taxpayer who may be liable to pay any internal revenue tax. Moreover,...
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What is the New Centralized Partnership Audit Regime?

The Internal Revenue Service has a new audit regime to administer. Taxpayers frequently have asked their tax attorney: what is the new BBA centralized audit regime? Also, how will the new BBA audit regime impact their partnership? Moreover, taxpayer’s ask whether a partner can file an inconsistent tax return. The Bipartisan Budget Act of 2015...
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IRS CDP HEARINGS AND TAX COURT LITIGATION

Taxpayers often ask their tax attorney what they can do to dispute a tax liability or collection action when they receive an IRS Final Notice of intent to levy or Notice of Federal Tax Lien. Additionally, taxpayers ask what options they have in an IRS CDP hearing. Internal Revenue Code (IRC) section 6320 provides a...
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How did AB5 Change California Worker Classifications?

A common question that taxpayers ask their tax attorney is whether a worker is an independent contractor or employee. In addition, what are the boundaries to that distinction? What are the factors? What if the worker prefers to be an independent contractor, has her or her own business, works for several employers simultaneously, and has...
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