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Offer in Compromise Calculation Explained by Denver Tax Attorney

How much will the IRS accept to settle my tax debt through an offer in compromise?  How much will my offer in compromise be?  These are common questions a Denver Tax Attorney at The McGuire Law Firm may be asked.  In some respects, we answer each question the same initially, but our final and true […]

Corporate Liquidation and Assumption of Debt Discussed by Denver Tax Attorney

When a corporation liquidates, what happens to the corporate debt?  This is a common question many of our clients will ask a tax attorney or business attorney at The McGuire Law Firm.  Our answer is usually, “it depends.”  While this is a typical (and maybe expected) answer from an attorney, it is correct.  The article […]

Form Over Substance by Denver Tax Attorney

The Form Over Substance Doctrine is a doctrine finding its foundation on equity principals.  Tax attorneys have seen the Internal Revenue Service (and courts) use the Form Over Substance Doctrine as a means by which to “attack” certain transactions.  Tax attorneys may have represented taxpayers in matters before the IRS when the IRS was attempting […]

Keeping Real Estate out of a C Corporation by Denver Tax Attorney

For many reasons tax attorneys and business attorneys may think it desirable to keep real estate out of a corporation.  The transfer or sale of assets, such as appreciated assets from a C Corporation leads to double taxation issues that are not found when the real estate is owned by individuals or a partnership.  Even […]

FTS Program Discussed by Denver Tax Attorney

A Denver tax lawyer at The McGuire Law Firm recently learned that the IRS Fast Track Settlement (FTS) program will be expanded nationwide.  As a  tax attorney John McGuire works extremely hard to stay up to date with all IRS notices and publications that may impact our clients.  Information regarding the FTS program is stated […]

2014 Inflation Figures Discussed by Denver Estate Planning Attorney

As a Denver Estate Planning Attorney,John McGuire looks forward to seeing what law changes Congress will make in the future. The article below discusses inflation figures for 2014. Recently the IRS released Revenue Procedure 2013-35, which notifies practitioners and taxpayers of the inflation-adjusted numbers for 2014. Below, please review a synopsis of the estate planning […]

Tax Attorney Discusses Substantial Economic Effect

Business owners may have heard about economic substance from their business attorneys or tax attorneys.  The Economic Substance Doctrine is a “test” by which the Internal Revenue Service will review certain transactions.  As a Denver tax attorney John McGuire has dealt with the Economic Substance Doctrine first hand for a number of clients and this […]

Denver Tax Attorney on IRS Installment Agreements

An installment agreement with the Internal Revenue Service is an agreement whereby a taxpayer agrees to pay a certain amount of money on or before a certain day of each month to satisfy their outstanding tax debt with the IRS.  As a Denver tax attorney, John McGuire has established many installment agreements with the Internal […]

Tax Attorney Discussion: Partnership’s Assumption of Liabilities

As a tax attorney and business attorney, John McGuire frequently works with a partner within a partnership who contributes property to a partnership such as an LLC and the partnership assumes the liability on the property.  When this occurs, a tax attorney will advise the contributing partner that their basis is decreased by the sum […]

IRC Section 752 Regulations Article by Denver Tax Lawyer

The 752 Regulations are used in determining a partner’s economic risk of loss for partnership debt.  These regulations apply a test to determine economic risk of loss by reviewing what the economic consequences would be to each partner if the partnership liquidated.  Thus, the partners risk is examined as if the partnership went through a […]