Tax Attorneys for Attorneys

Tax Attorneys for Attorneys

IRS Jeopardy Assessment

IRS Jeopardy Assessment



Far removed from the full-filled half hour that we associate with a Merv Griffith-created game show called Jeopardy!, "jeopardy," when referring to the IRS, leaves little room for entertainment.  In fact, it can mark the beginning of an significant escalation of a tax problem.  You see, a “Jeopardy Assessment” is made when the IRS feels, (yes, the IRS has feelings)  it is at risk of losing its hard-earned money because a taxpayer (or someone who holds cash of another taxpayer) is going to take some sort of action that will make it difficult for the IRS later collect.

Oh Great. Now There Is A FATCA Scam Too

Oh Great. Now There Is A FATCA Scam Too



You may detect a
certain tone in this article regarding the FATCA scam, indicating that
this writer believes FATCA was a huge mistake. That detection would be
correct. Yet, while we may snark at Commissioner Koskinen
— who has the potential to break the irony meter with this quote, from
above: “[p]eople should always be cautious about sending sensitive
information to anyone.” In fact, the entire FATCA misery lands squarely
at the feet of those who voted for it. The IRS did not create FATCA, and
in fact, the IRS has introduced and is responsible for exactly 0% of
all tax laws. The IRS should not be the scapegoat, but rather the 217 Democrats in the House of Representatives, the 55 Democrats, 11 Republicans(!) and 3 independents in the Senate, and the one President who ratified this terrible, terrible bill.

OVDP streamlined procedures willful blindness

OVDP streamlined procedures willful blindness



"The IRS is not a person. It does not have a conscience. It does not
stay up at night worrying if people like it. The IRS is simply a system
where people follow orders.  In all reality, the IRS has no problem
ruining you. And the naivety of otherwise smart, intelligent,
hard-working people to understand this —  well, this — you even have
that nightmare where you’re trying to yell to a loved-one so they can
avoid impending harm, but you can’t make a sound? Well that’s what it
seems like some days when people tell us they are going to try handling a
problem themselves or with an under-powered representative."

Calculating a willful FBAR penalty

Calculating a willful FBAR penalty



The purpose of the FBAR form was to give Treasury an E-Z way to penalize
the worst of the worst. But the worst of the worst, if they read the
law carefully can avoid having a foreign account with any balance
subject to an willful FBAR non-filing. You see, 50% of $0 = $0 Sure,
there are a whole bunch of other laws being broken, but isn't the entire
rationale for requiring self-reporting of foreign bank account
completely undermined? 

Estimated Tax payments

Estimated Tax payments



In a perfect world, no one would ever run
short of cash and there would be enough to pay everyone. But that isn’t
reality, is it? So at some point, you need to prioritize. Should you
pay an old tax debt or  your current payments? Should you pay other debt
or your estimated tax payments. Here is the most important thing I want
you to get form this article: When push comes to shove, pay your current estimated tax payments first! Old tax a debts can all be negotiated. Future tax problems can not be.

Winning IRS Offer in Compromise collateral agreement strategies

Winning IRS Offer in Compromise collateral agreement strategies

Willful FBAR Penalties – How they happen and how to avoid

Willful FBAR Penalties – How they happen and how to avoid

Was your IRS OVDP declined?

Was your IRS OVDP declined?