Author Archives: Patricia Weisgerber

Smith v. Comm’r: Before You Take that Business-Related Tax Loss, Ask “Does My Business Have a Bona Fide Purpose?”

By Patricia Weisgerber, Esq., LL.M. Last fall, the U.S. Tax Court decided the case of Smith v. Comm’r.[1] It’s not a pivotal case, but it stands as a good reminder of the adage “you don’t get something for nothing.” At the heart of the case was a complicated tax ...

IRS Notice 2018-01: Passport Denial/Revocation for “Seriously Delinquent Tax Debts” to Begin

by Patricia Weisgerber, Esq., LL.M. In 2015, the Fixing America's Surface Transportation (FAST) Act contained a provision in which the IRS would interact with the State Department to deny or revoke the passports of taxpayers with "seriously delinquent tax debts." However, details needed to be worked out between the two agencies before the ...

Estate and Gift Tax Audits: TIGTA Report Exposes Need for Improvement

by Attorney Patricia Weisgerber, LL.M. While proposals for the eventual elimination of the estate tax are being hashed out in Congress, the IRS effort of auditing estate tax returns continues - business as usual. A ...

International Tax Issues Are A Major Focus of Newest Launch of IRS Compliance Campaigns in 2017

by Attorney Patricia Weisgerber, LL.M. Earlier this year, the IRS Large Business and International division (LB&I) rolled out 13 compliance campaigns[1] to target both individual taxpayers and corporations for examinations on certain tax compliance issues. On November 3, 2017, IRS announced the identification of an additional 11 compliance campaigns ...

Are Your Business Deductions at Risk of Being Disallowed by the IRS?

by  Attorney Patricia Weisgerber, LL.M. Small businesses run on tight margins. The last thing a business owner wants is an IRS notice announcing the disallowance any of their business expense deductions. This is particularly the case for sole proprietorships who report their business expenses on Schedule C of IRS Form 1040. For ...

UPDATE: MTC Extends Deadline for Amnesty under the Online Marketplace Seller Voluntary Disclosure Initiative

Earlier today, the Multistate Tax Commission (MTC) released an update extending the October 17, 2017 deadline for businesses to file under its Online Marketplace Seller Voluntary Disclosure Initiative. The new deadline is now November 1, 2017. This initiative is specifically for businesses who are online marketplace sellers using a marketplace provider/facilitator ...

An Overview of the Unified Republican Framework on Tax Reform

On September 27, 2017, President Trump and the Republicans unveiled the elements of their tax reform framework. Here’s a quick overview of some of the proposed changes: Individual Taxes Standard Deduction: Under the proposed framework, that standard deductions will approximately be doubled to:
  • $24,000 for married taxpayers filing jointly, and
  • $12,000 for single
...

Tax Relief for Hurricane Harvey and Irma Victims

The IRS is offering tax relief for taxpayers affected by Hurricanes Harvey and Irma. This relief is automatic for those taxpayers located in designated disaster areas. These areas include Florida, Georgia, Puerto Rico, the Virgin Islands and parts of Texas. In general, the IRS is providing extensions until January 31, 2018 ...

The Importance of Timely Electing Your Foreign Earned Income Exclusion

by Attorney Patricia Weisgerber, LL.M. Life as an American living abroad can conjure idyllic notions of painting en plein air in Paris or negotiating a last minute deal in Brussels. Not so idyllic, however, is the reality of filing U.S. tax returns from overseas. One of U.S. taxpayers living abroad is ...

SCORE! for the Boston Bruins – Jacobs v. Commissioner

by Attorney Patricia Weisgerber, LLM Like Napolean recognizing that an army marches on its stomach, the owners of the Boston Bruins know a hockey team needs to be well-fed to ensure optimal performance on game day. So, when the Bruins go on the road to play away-games, management plans ahead. With ...