Tag: Bluestein and Weber PC

8
Aug

IRS Penalty Abatements

The practitioner’s guide to Federal Tax Penalties and how and when to request abatement By Deborah J. Weber There are approximately 150 penalties contained in the Internal Revenue Code. This article is not intended to address every penalty contained in the Code, but rather, will focus on the more mainstream penalties encountered frequently in practice. Civil penalties are obviously designed to

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8
Aug

IRS Statutes of Limitations

By Gary Bluestein There is no greater pitfall for a practitioner than missing an applicable statute of limitations for a client. Professional judgment can usually be defended. The style and content of a submission are subjective. But a statute of limitations is a bright line for all to see and each practitioner should always be aware of where those lines

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8
Aug

New York State Sales and Use Tax Audits

Defending Clients’ Sales & Use Tax Audits Against NYS By Deborah Weber Various new enforcement initiatives have been undertaken by the New York State Tax Department in the past year with many enforcement initiatives focused on sales and use tax audit and collection. The purpose of this article is to provide the background and explanation of these new initiatives, discuss the

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8
Aug

Nominees Liens and Alter Egos

By Gary Bluestein 5.12.1.2.11 Nominee and Alter Ego Situations (12-01-2006) Persons identified as nominees or alter egos are not entitled to a Collection Due Process Hearing. If a nominee or alter ego is sent Letter 3177, Notice of Federal Tax Lien Filing – Nominee and Alter Ego… there is no requirement to send this notice certified mail. The person identified

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7
Aug

Offer In Compromises with the IRS

By Deborah J. Weber The Government, like other creditors, encounters situations where an account receivable cannot be collected in full (especially in the current economic climate) or there is a legitimate dispute as to what is owed. The IRS, with the permission of Congress, has accepted the business practice of compromise of liability in certain circumstances with the creation and implementation

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7
Aug

Preparing Financial Statements for the IRS

How to assist your clients in completing optimum financial information statements, offers in compromise and installment payment agreements By Deborah J. Weber The Internal Revenue Service has two Financial Information Statements and one Collection Information Statement. The Form 433-A is the Financial Information Statement for Individuals and the Form 433-B is the Financial Information Statement for Businesses. The Form 433-F is

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7
Aug

The Trust Fund Recovery Penalty

When can the IRS pierce the corporate veil and what you can do if it does A Tax Article for Corporate and General Practice Attorneys By Deborah J. Weber As a corporate or general practice attorney, you no doubt recommend that your client incorporate or form a limited liability company in an effort to limit personal exposure for both acts of

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7
Aug

Working with Nonfilers – Strategies to Avoid Prosecution

By Deborah J. Weber Where to begin with the non-filer: Non-filers generally come in two different categories: worried, distraught and ready to come forward; or arrogant, stubborn and needing to be convinced. For the worried, distraught individual, very little convincing is necessary to have the client come forward to the IRS. However, for the arrogant and/or stubborn individual, a little more

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