Tax Blog/Blawg

When the IRS reaches (in the words of Tax Court Judge Mark Holmes) the “we're taking your stuff” stage to collect back-taxes, taxpayers generally have the right to a collection due process (CDP) hearing at which a CDP hearings officer is duty-bound to independently and genuinely evaluate whether it’s proper for the IRS to move forward with seizing a taxpayer’s property.  On May 20, 2021, the Tax Court, in Mason v. Commissioner, concluded the IRS had abused its discretion in the CDP process when it gave the green-light to the IRS collection division to take the taxpayer’s stuff ...

London’s Underground (which is a subway to us Yanks) is known for its iconic warnings to “mind the gap.”  That’s the spatial crevice between the train and the station platform.  In D.C., a different gap is garnering attention: the tax gap.  This is the delta between taxes owed to the government and actually paid.

On May 20, 2021, as part of the Administration’s pitch for an $80 billion increase in IRS funding, Treasury released a report that outlines the magnitude and categorical causes of the tax gap, and in broad strokes how it would deploy the $80 billion over a 10-year period to ...

Section 1031 “like-kind” exchanges have long been a useful tool for family and closely held business planning. For example, business enterprises have been able to exchange commercial or industrial buildings for larger facilities without incurring current tax liability. Similarly, individuals who have owned and operated rental property but no longer are able or wish to manage such property have utilized Section 1031 to exchange their property for “net leased” replacement property, thereby obtaining a dependable stream of rental income and deferring taxation of ...