Category Archives: Tax Planning

Taxpayer Tips: Best Practices for U. S. Tax Court

Taxpayers contesting IRS assessments of additional taxes, penalties and interest have a number of different options to contest and appeal those assessments. One of those options includes bringing a case to the United States Tax Court (Tax Court). Here are some Tax Court practice tips for taxpayers:

1. Know What Tax ...

Federal Tax Reform Legislation in 2017: Comments by Attorney Morris N. Robinson

Attorney Morris N. Robinson, the Managing Director of M. Robinson Tax Law in Boston, recently published an op-ed titled: Viewpoint: A 15 percent tax rate on business would maximize economic growth (Boston Business Journal, May 5, 2017, subscription required).

IRS Targets Globally-Mobile Individuals and Businesses: The Importance of Proactive Planning

IRS Targets Globally-Mobile Individuals and Businesses:

The Importance of Proactive Planning

By Attorney Morris N. Robinson, CPA, LLM

April 21, 2017

IRS targets globally-mobile individuals and businesses through its Global High Wealth Industry Group and its Large Business and International Division. Targeted taxpayers find these audits ...

IRS is Hacked, Again!

IRS is Hacked, Again!

The Massachusetts Tax Alert™

Yale Yechiel N. Robinson, Esq.

April 7, 2017

            The New York Times reported yesterday that identity thieves may have compromised up to 100,000 U.S. taxpayer accounts.  The criminals apparently took advantage of a software tool that ...

IRS Targets the Wealthy via Wealth Squad

IRS Targets the Wealthy via Wealth Squad

By Attorney Morris N. Robinson, CPA, LL.M.

April 6, 2017

IRS operates a Wealth Squad, which brings together teams of IRS specialists to coordinate the audit of wealthy taxpayers. IRS identifies wealthy “targets” with secret algorithms that are skewed against ...

IRS Begins Private Debt Collection of Back Taxes: What You Need to Know

IRS Begins Private Debt Collection of Back Taxes: What You Need to Know

The Massachusetts Tax Alert™

Yale Yechiel N. Robinson, Esq.

April 5, 2017

            The IRS announced on April 4, 2017 that it will soon authorize four private debt collection companies to send ...

For High-Income and International Taxpayers: Defensive Tax Planning

For High-Income and International Taxpayers: Defensive Tax Planning By Attorney Morris N. Robinson, CPA, LLM[1] March 31, 2017 The Importance of Defensive Tax Planning IRS audit criteria target high-income taxpayers, especially those with reported foreign income or foreign financial assets. Targeted high income taxpayers include:
  • Individuals
  • Trusts and Estates
  • Corporations
  • Partnerships and LLCs
What ...

Net Operating Loss Carryforwards on President Trump’s 2005 Income Tax Return

James B. Stewart, writing for The New York Times (March 23, 2017), explored the complexities of President Donald Trump’s 2005 U.S. income tax return, which was revealed publicly last week.  President Trump used $103 million of net operating loss (NOL) carryforwards in 2005 to reduce his regular income tax. ...

Personal Liability of Executors for Tax Liabilities of the Estate Under the Federal Priority Statute, 31 U.S.C. 3713

United States v. McNicol 829 F.3d 77, (1st Cir. July 15, 2016) aff’g 2014 WL 4384486, 114 A.F.T.R. 2,d 2014-5919 (D. Mass., 2014) Summary This is an appeal of summary judgment by the personal representative (the “PR”) of an estate. The lower court found the PR to be personally liable under the federal ...

Statute of Limitations and Collections Process Against Executrix and Agent for Estate Tax Deficiency

United States v. Holmes 2016 WL 4363398 (SD Tex. Aug. 16, 2016) Summary Summary judgment was sought by both the taxpayers and the Government for an estate tax liability. The taxpayers contended that the 10-year statute of limitations on collections had expired. The Government disagreed and put forth that the statute of ...