Once again, the Tax Court has dealt with a remarkably vexing issue: whether an overstatement of basis should allow the IRS to extend the statute of limitations for the assessment of tax from three years to six. Intermountain Insurance Service of Vail LLC v. Commissioner (134 TC No. 11 (2010)) adds to an increasing body of case law against the IRS. Tax advisors should expect the IRS to get off the mat and continue to challenge taxpayers. The background and evolution of this issue are fascinating because they involve the struggle to interpret relatively straightforward words in a fundamental, procedural statute. If a taxpayer "omits" from gross income an amount properly includable therein which exceeds 25% of the amount of gross income stated in the return, the limitations period for asse...
... attempting to evade or defeat the assessment of atax as well as the offense of willfully attemp..., required or authorized to be madeas the basis of an application to reduce any tax or assessment,...
The "Downtown" that Petula Clark evoked in her 1964 pop song of that name (where "you can forget all your troubles, forget all your cares") never made much sense to anyone who worked or lived in an actual downtown. It was a song for people who did not. With a political future to consider, Mr. [Thomas R. Suozzi] voiced many of the same convictions, but with a different emphasis on the preeminent suburban political issue, which is taxes. By building apartments near commuter rail lines and attracting young people to suburban downtowns with "fantastic restaurants and small shops," he said at the conference, "our major purpose is to expand our tax base and lower taxes. At times, they erupted in applause when speakers uttered phrases like "commercial-facadeimprovement tax districts," or "ben...
... tax districts," or "benefit-assessment-basis taxation." The notion of "multiyear capital ...
While it is the substance of the dispute that determines the outcome at any stage of the tax audit and adjudication process, the substance is irrelevant, and resolving the matter hopeless, unless the dispute is properly placed before a tribunal with jurisdiction to resolve it. Whenever a taxpayer receives a notice of an audit, the first step is to determine the statute of limitations date for assessment of the tax. If the return is fraudulent, their is no statute of limitation for a civil assessment. Once a notice proposing an assessment is mailed, it must be formally protested in order to preserve the taxpayer's right to present opposition to the assessment. If the parties reach an agreement with the conferee, the conferee will issue a consent which, upon execution, will finally determ...
... determine the tax in the amount and on the basis set forth in the consent. Great care must be taken...
Both plans involve significant changes to the federal tax system, as The Heritage Foundation's Center for Data Analysis details in a new overview and assessment of their respective economic effects [www.heritage.org]. The Obama plan also suffers by proliferating and expanding refundable tax credits, which further - and inappropriately - transform our income tax system into an incomesupport system. [...] the Obama plan raises income tax rates, raises payroll taxes on a delayed basis and actively increases use of the tax system to redistribute income to those who pay little or no income tax - helping them by spreading Joe's and others' wealth around, as Obama earnestly explained.
... of each income tax position on a MLTN basis every quarter leads to substantially more volatili... issue-by-issue basis, including a self-assessment of the evidence supporting their positions. Hence,...
Because income taxes are self-assessed in most tax jurisdictions, a company may take a position on its tax return that allows it to claim a tax benefit minimizing its tax liability. In response, FASB issued Interpretation (FIN) 48, Accounting for Uncertainty in Income Taxes. It contains guidance on the recognition and measurement of all tax positions accounted for in accordance with SFAS 109. FIN 48 requires a company to accrue interest and penalties when there is underpayment of taxes. The overall impact of FIN 48 is that, on average, a smaller amount of tax benefit will be recognized in companies' financial statements in the current period. Companies will need to identify significant tax positions and differentiate uncertain positions from unambiguous ones that would not require FIN 4...
... record the tax benefits on an "as-filed" basis. That is, any current or deferred tax assets or li... than not represents a probability assessment of greater than 50%. The determination of whether ...
... That premise finds no basis instanding jurisprudence. This Court has sometime... and Remonstrance AgainstReligious Assessments. DaimlerChrysler, supra, at 348.In 1785, the Gener...
... for the unpaid balance of the assessment. Respondent moved to suppress the evidence seized ... proceedings, it was agreed that the "sole basis of the computation of the civil tax assessment . ....
... Respondent taxpayers overstated the basis of certainproperty that they had sold. As a resul...30. The Commissioner's assessment came after the ordinary3-year limitations period...
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