On behalf of Janathan L. Allen, APC posted in Tax Controversy on Wednesday, June 11, 2014. Imagine you are approaching your retirement. After years and years of work and saving, you've finally reached the point in your life where you can leave the workforce behind and enjoy your remaining years...
Which IRS Program is Best for Those Who Have Issues with FBARs?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Monday, December 29, 2014. The IRS has two main options for those who have either under-reported or failed to report foreign accounts or assets on the FBARs associated with their returns. The first option is the...
When Are Tax Returns Confidential And Privileged From Production? (Part 2)
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in California Tax on Thursday, December 11, 2014. Company Protected Against Forced Disclosure of Tax Returns In Casa W LLC v. Superior Court of Los Angeles County et al., Kyle Madison, his former wife Marjan Madison, and their friend...
When Are Tax Returns Confidential And Privileged From Production? (Part 1)
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in IRS on Wednesday, December 10, 2014. California is one of the few states that holds tax returns may be privileged and not subject to discovery during civil litigation, except under certain circumstances. The privilege applies to both state...
Treasury Inspector Says IRS Can Improve Processing of Frozen Credit Accounts
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in Tax Controversy on Tuesday, December 23, 2014. While the IRS does have certain procedural requirements and standardized systematic checks in place to identify and resolve most frozen credit accounts, the recent Treasury Inspector General for Tax Administration (TIGTA)...
The Effects of the Foreign Account Tax Compliance Act
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Sunday, December 21, 2014. The Foreign Account Tax Compliance Act, or "FATCA" as it is known, passed in March 2010, "targets tax non-compliance by U.S. taxpayers with foreign accounts." The FATCA is concerned with reporting by...
Taxpayer Cannot Avoid IRS Mail And Later Challenge Tax Liability (Part 2)
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in California Tax on Wednesday, December 17, 2014. Tax Court Holds Mr. Onyango Cannot Dispute 2006 Tax Liability Mr. Onyango argued that he could challenge his 2006 tax liability under the tax code section allowing a taxpayer to challenge...
Taxpayer Cannot Avoid IRS Mail And Later Challenge Tax Liability
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in Audits on Tuesday, December 16, 2014. Anytime a taxpayer is contacted by the Internal Revenue service, the taxpayer should take notice. The failure to timely respond or even respond at all can have significant consequences for a taxpayer....
Netflix Claims That Former Officer Received Improper Kickbacks
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in Business & Contracts on Friday, December 26, 2014. Netflix Inc. has filed a lawsuit against Mike Kail, its former Vice President of IT operations, claiming that he improperly accepted kickbacks from vendors. Mr. Kail is now the Chief...