The IRS has recently issued an ominous notice (#IR-2023-126) in which the IRS warns high income US taxpayers and millionaire non-filers that the IRS is targeting them to conduct audits, identify and collect undeclared income and unpaid taxes while considering criminal tax evasion charges in many cases. The IRS discusses...
ABCast Episode 2 – the Process of an IRS Audit
ABCast Episode 2 focuses on "the Process of an IRS Audit." San Diego tax attorney Janathan Allen discusses what a US taxpayer needs to understand about an IRS audit, their rights as a taxpayer and how to handle themselves. This podcast discusses what to do from the moment you receive...
Did You Receive an IRS Notice of Deficiency?
Did you receive an IRS Notice of Deficiency in the mail? What is an IRS Notice of Deficiency and is this important? If you have received an IRS Notice of Deficiency you are facing immediate modification of prior tax returns, and exposure to IRS collection tactics. The IRS Notice of...
Come Into Compliance with IRS and FBAR Reporting
What should you do if you need to come into compliance with IRS and FBAR reporting? There are 3 options for coming into compliance with your obligation to report offshore asset holdings: The Voluntary Disclosure Practice or VDP, the Streamlined Filing Compliance Procedures or SFCP, or the delinquent FBAR and...
What is the IRS Audit Statute of Limitations
What is the IRS audit statute of limitations? Is there a time limit placed upon the IRS when it comes to auditing your tax returns or collections of tax related debt? The answer is "yes" and this time limit is known as a "Statute of Limitations." Traditionally, the IRS Statute...
What is the Difference Between an IRS Levy and a Lien?
What is the difference between an IRS levy and a lien? In the simplest of terms, the difference between a levy and a lien is that a levy actually takes property or money from your account(s) to pay for the tax debt you owe while a lien creates a legal...
Why the Attorney Client Privilege Matters in IRS Issues Involving Foreign Assets
It is important to understand why the attorney client privilege matters in IRS issues involving foreign assets. The attorney-client privilege is a solid legal protection that allows a client to discuss the details of foreign accounts and assets with our experienced tax attorney Janathan Allen without concern of disclosure to...
What Do You Need to Know When Corresponding with the IRS
What do you need to know when corresponding with the IRS? When it comes to dealing with the IRS, a lot of people are filled with fear. That's understandable simply because the reputation that the IRS has made for itself certainly doesn't lend to the agency being a particularly nice...
Many Penalties Accrue When You Fail to File Taxes
Did you know that many penalties accrue when you fail to file taxes? Imagine that you are filing your taxes, and during the course of filing these taxes you discover that you will actually owe the Internal Revenue Service some money. No refund for you -- instead, you have yourself...