26 USC § 6103 – Confidentiality and disclosure of returns and return information – provides that a taxpayer’s tax return information shall be confidential: a) General rule Returns and return information shall be confidential, and except as authorized by this title — (1) no officer or employee of the United States, (2) no officer or [...]
Tags: IRS Audits · IRS procedure
The Wall Street Journal reports in IRS Ramps Up Audits of Wealthiest that “the IRS expanded its audits of Americans earning more than $500,000 last year, with a stark increase for those making more than $1 million:” The agency, in an annual report released Thursday, said it performed audits in the year ended Sept. 30 on 5.4% [...]
Tags: IRS Audits
By way (once again) of Paul Caron (emphasis is mine): Smith: The APA’s Reasoned-Explanation Rule and IRS Deficiency Notices Patrick J. Smith (Ivins, Phillips & Barker, Washington, D.C.), The APA’s Reasoned-Explanation Rule and IRS Deficiency Notices, 134 Tax Notes 331 (Jan. 16, 2012): The D.C. Circuit’s confirmation in Cohen that the Administrative Procedure Act (APA) applies to [...]
Tags: IRS Audits · IRS procedure · tax court
The AP reports that the IRS has continued to allocate more of its resources to the examination of the tax returns of the super rich: One in eight people earning at least $1 million annually was audited by the Internal Revenue Service last year, making them far likelier to be examined than those making below $200,000, [...]
Tags: Announcements · IRS Audits · News · Politics of Taxes
The Treasury Inspector General for Tax Administration says the IRS needs to improve the quality of its audits of small corporations. Listen: TIGTA reviewed whether IRS examiners followed proper procedures and guidelines when auditing the returns of small corporations. The IRS defines small corporations as corporations with assets of less than $10 million. Many corporations in the [...]
Tags: Announcements · IRS Audits · S Corporations
Taxpayers and their advisors have good reason to want to categorize losses as theft losses rather than investment losses. Theft losses are treated as ordinary losses and are deductible in the year incurred.¹ Investment losses are treated as capital losses and are limited to the amount of capital gains plus $3,000. It is, therefore, not surprising that TIGTA has [...]
Tags: Announcements · Deductible Expenses · IRS Audits · News
Accounting Today reports that one of Switzerland’s oldest banks, Clariden Leu, has become the latest to cooperate with U.S. tax authorities in disclosing the names of American investors: The bank has begun notifying some of its U.S. customers that it plans to reveal their names and account information to the Internal Revenue Service, according to [...]
Tags: Announcements · International Taxation · IRS Audits · News · Tax Crimes
