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Non-willful conduct is required under the Streamlined Offshore Voluntary Disclosure Program (Streamlined OVDP).  If the failure to report foreign bank accounts and/or foreign financial assets was non-willful, you may be subject to a lower penalty base.  The key question is, what constitutes non-willful actions by a taxpayer?  Generally, the IRS would consider non-willful to mean...
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As taxpayer you have the right to notice and a hearing prior to the IRS enforcing collection of any tax due.  After the IRS has issued a series a notices, the IRS must issue a Final Notice of Intent to Levy and allow you 30 days to request a hearing, which is generally referred to...
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When an asset is placed into service and depreciation is taken as a deduction, the adjusted basis of the asset will be impacted.  The video below has been prepared by a tax attorney at The McGuire Law Firm to discuss this issue.  Please remember to always consult your tax attorney, business attorney, CPA and/or other...
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When forming a partnership the partners will make initial capital contributions and may make additional contributions depending upon the operations of the partnership and partnership agreement.  Common capital contributions may include cash, property (vehicles, equipment, computers etc.) and sometimes services. The video below has been prepared by a tax attorney and business attorney at The...
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If you are under audit by the IRS, have received a notice of deficiency or the IRS is attempting to collect past due taxes, you can receive representation.  The video below has been prepared by a tax attorney at The McGuire Law Firm to provide information regarding who can represent you before the Internal Revenue...
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A taxpayer has the right to a collection due process hearing with the Internal Revenue Service Appeals Office under certain circumstances.  This hearing can be very beneficial to a taxpayer in terms of preventing enforcement action such as a bank levy or wage garnishment and by a means to establish or propose an agreement with...
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What are my rights as a taxpayer?  What appeal rights do I have regarding IRS actions or decisions?  These are common questions a taxpayer may have when a tax liability is owed to the IRS and the taxpayer is in the collection process with the IRS.  The information below has been provided for general information...
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Can I deduct my meals as a business expense?  Can I deduct this flight as a business expense?  Can I deduct the cost of my clothes or uniform as a business expense? As a tax attorney, these are common questions I am asked, and rightfully so as everyone wants to take advantage of all potential...
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Individuals holding property for rent. Rental properties can make good investment options as they diversify an individual’s overall portfolio, the mortgage can often be satisfied by the rental payments as equity grows in the property, and with the allowable deductions, including depreciation, a loss may exist that allows the individual to lower their total income...
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What is the effect of an individual’s residency and the application of estate taxes? This may be an issue that does not apply to you or your clients because you or your client is a citizen of the United States and thus the law is relatively clear that tax on the individual’s estate is subject...
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