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Articles by Josh Ungerman
Hobby Loss And Ranches - An Overview Of Section 183
If a taxpayer undertakes an activity with the objective of making a profit, the expenses related to the activity are generally deductible and any excess losses related to the activity can be utilized in future tax years (subject to applicable net operating loss limitations). If the activity is deemed to be subject to the "hobby loss rules" of Internal Revenue Code Section 183, however, the expenses and losses related to the activity are generally disallowed.
IRS Doubles Down On Pursuing High-Income Non-Filers
Despite the demands of Covid, the IRS is on the hunt for high income non-filers. Getty Images Eric Hylton, the commissioner of the Internal Revenue Service Small Business/Self-Employed Division, threw down the gauntlet December 3, 2020 with an article the IRS pushed out on its newswire on how the IRS views high-income non-filers.
Taxpayers Who Filed Tax Returns In U.S. Virgin Islands Enjoy Victory Against The IRS
For some time now, the IRS has scrutinized taxpayers who participate in the USVI Economic Development Commission (EDC) program. As a result, EDC participants have been subject to countless IRS examinations and potential new participants have been reluctant to invest on the islands. The issue came down to how long IRS had to challenge tax returns claiming the benefits from EDC investments. Back in 2013 the U.S. Tax Court in Appleton v.
IRS Criminal Investigation Is Still Active Despite Fewer Investigations - Ask Caterpillar
IRS Criminal Investigation (CI) recently released their 2016 Annual Report. The report tries to put the best face on the continually diminishing number of investigations. From 2013 through 2016, the number of investigations initiated by IRS CI has dropped an amazing 36%. During that same time period, the number of IRS Special Agents has dropped almost 13%. The investigations initiated are only a portion of the story.
IRS Commissioner Admits Defeat
Too many taxpayers and a handful of unscrupulous "tax practitioners" are taking advantage of the almost absolute absence of tax enforcement by the IRS. Will we look back on this time and reflect that Commissioner Koskinen wasn't crying that the sky was falling but instead underestimated the loss of revenue when he only pegged it at $5 billion a year?
Caribbean Vacation -- Don't Book That Trip Yet. If You Owe The IRS, Your Passport May Be Revoked
The FAST Act, enacted on December 5, 2015, allows the IRS, for the first time, to share information with the State Department. This sharing provision opens the door for the State Department to take action against U. S. taxpayers who owe money to the IRS by revoking their existing passports or refusing to issue or renew a passport.
Three Traps for the Unwary
Employers and responsible individuals within a business can be held personally liable for withheld payroll taxes that are not timely turned over to IRS. In advising small businesses who may be considering "making themselves loans" or actually diverting their employees' withheld funds, there are three big traps for the unwary the IRS is using to establish knowledge in criminal employment tax prosecutions.
If You Owe Under $1 Million, The IRS May Not Visit You
For the past few years it has been in vogue for some segments of the population to bash the IRS and call for decreased funding if not outright abolishment. The IRS, like many large organizations, has fought to control its small sliver of problematic employees and increase efficiency. The problem is that the IRS, unlike other large organizations, is responsible for collecting the revenue that runs the country. When Congress “guts” the IRS like it has over the recent past, what is the likely result?
IRS Expected To Issue Hundreds Of Deficiency Notices TO USVI Residents
The purpose of a Statutory Notice of Deficiency (SND or 90-Day Notice) is to ensure the taxpayer is formally notified of the IRS’s intention to assess a tax deficiency. The SND is a legal determination that is presumptively correct and informs the taxpayer of the opportunity and right to petition the Tax Court to dispute the proposed adjustments. IRS is expected to issue SNDs to United States Virgin Island residents in the next few months – Will the Estate of Sanders opinion stop the IRS?
IRS Approach To Taxation of Bitcoin
The IRS approach to the taxation of crypto currencies like Bitcoin may turn into an accounting nightmare for all but the most casual of users. Virtual currencies, such as Bitcoin, are becoming useful tools in the digital age. In essence, a virtual currency is a currency that exists only in cyberspace and is not backed by any government. The value often fluctuates by the hour and there is no coin or certificate to touch.
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