Author Archives: Russ

What Portion of the Stipulation Didn’t You Read?

A company owes withholding tax to the IRS. The case goes to Tax Court, where the issues are resolved, including a stipulated amount of withholding. Somehow the IRS forgets about the withholding. It then goes to a collection Appeals, where … Continue reading →

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IRS Mostly Wins Coinbase Summons Fight

The IRS has been battling Coinbase, the United States’ largest cryptocurrency exchange, in a fight to obtain information about individuals who sold Bitcoins during 2013, 2014, and 2015. The IRS issued a summons to Coinbase–basically, an administrative demand for information. … Continue reading →

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Law 1, Seattle 0

Earlier this year the city of Seattle unanimously passed a city income tax into law. The tax would be 2.25% on total income above $250,000 for individuals and on total income of $500,000 for married filing jointly. The law was … Continue reading →

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“Hello, It Has Been Detected That You Are a Scammer….”

After recovering from a bout with the flu I attended continuing education yesterday with the Nevada Society of Enrolled Agents. We had a presentation from a Special Agent with TIGTA (the Treasury Inspector General for Tax Administration). One of the … Continue reading →

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GOP Tax Proposal Targets Professional Gamblers’ Losing Years

The Joint Committee on Taxation released its new tax proposal, H.R. 1, today. Buried within it is Section 1305: SEC. 1305. LIMITATION ON WAGERING LOSSES. (a) IN GENERAL.—Section 165(d) is amended by adding at the end the following: ‘‘For purposes … Continue reading →

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Israel Tax Authority Targets Poker Professionals

Some unknown bureaucrat working at the Israel Tax Authority was likely reading something about poker or perhaps watching the World Series of Poker on television when he asked himself, “I wonder if Israeli poker players are paying their income taxes?” … Continue reading →

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The Shortest Tax Court Opinion I’ve Seen

I’ve seen opinions of the Tax Court run to hundreds of pages on complex cases. Today, I perused what might be the shortest Tax Court decision I’ve ever seen. The petitioner erroneously filed as “Head of Household” when she should … Continue reading →

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IRS E-Filing for Individuals Closes on November 18th

The IRS announced today that e-filing for 2016 tax returns will close on Saturday, November 18th. After that date individuals who need to file 2016 tax returns will need to paper-file those returns until e-filing reopens (most likely in late … Continue reading →

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FBAR Snags Manafort

Paul Manafort, Jr. and Richard Gates III were indicted on Friday. The 12-count indictment alleges “[C]onspiracy against the United States, conspiracy to launder money, unregistered agent of a foreign principal, false and misleading FARA statements, false statements, and seven counts … Continue reading →

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Reason Magazine on Gilbert Hyatt vs. California’s Franchise Tax Board

Reason magazine has a superb presentation on Gilbert Hyatt’s battle with California’s Franchise Tax Board. I cannot recommend it highly enough:

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