The document discusses taxpayers' rights when dealing with an IRS audit. It outlines 10 key rights taxpayers have, including the right to be informed, the right to quality service, and the right to appeal an IRS decision. It also provides tips for dealing with an IRS audit notice, such as not ignoring it, reading it closely, and knowing applicable deadlines. Additional sections cover taxpayers' rights to challenge IRS positions, retain representation, and expect a fair tax system. The document aims to educate taxpayers on their protections during an IRS examination.
This document provides an overview of personal taxes in the United States. It discusses the major types of taxes individuals pay, including taxes on purchases, property, wealth, and earnings. It explains how the federal income tax is calculated, including determining taxable income, deductions, credits, and the taxes owed. It also reviews strategies for tax planning, preparing and filing tax returns, and what to do if your return is audited. The overall goal is to help people understand their tax obligations while taking advantage of available tax benefits.
Onboarding a new tax representation client involves several key steps: checking for conflicts of interest, obtaining an engagement agreement that defines the scope of work, conducting a tax compliance check using IRS transcripts, helping the client become fully tax compliant, determining if the IRS balance is accurate and reviewing collection alternatives or deficiency resolution options, which may require preparing IRS Form 433 financial statements. The overall goal is to properly define the representation and resolve the client's tax issues.
The document summarizes key aspects of procedures and precedents in U.S. Tax Court. It describes the Tax Court's structure and jurisdiction over tax deficiency cases. It explains procedures for docketing cases, discovery, pre-trial memoranda, and precedent from appeals. The document also covers the small tax case procedure and calendar calls. Finally, it discusses the review process for cases decided by special trial judges.
The document summarizes key aspects of tax administration and planning according to US law. It describes the organizational structure of the Internal Revenue Service (IRS) and its audit processes. It also outlines taxpayer penalties, statutes of limitations, the roles of tax practitioners, and concepts of tax planning to minimize liability legally.
This document provides an overview of installment agreements, which allow taxpayers unable to fully pay their tax bills to pay over time. It discusses what an installment agreement is, the application process, and factors the IRS considers in approving agreements. The IRS may automatically approve agreements for under $10,000 or streamlined agreements up to $50,000. For larger amounts, taxpayers must submit financial information for the IRS to determine their ability to pay based on assets and disposable income. Installment agreements aim to allow taxpayers to pay what they can reasonably afford over time without jeopardizing their livelihoods or earnings.
The document discusses the structure and responsibilities of the Internal Revenue Service (IRS). It covers how Congress creates tax law that the IRS enforces through departments that process tax documents, audit returns, and collect taxes owed. It also summarizes taxpayers' rights and responsibilities in dealing with audits, penalties for noncompliance, and the statute of limitations. Key aspects of tax preparation, tax planning and avoidance of "tax traps" are also addressed.
Ayar law-Delinquent business tax collections MICPAVenar Ayar
Case Study of what the IRS will do and how they will collect your tax dollars owed. When the worst happens call Ayar Law. Don't face your tax problems alone we will help.
This document provides an overview of personal taxes in the United States. It discusses the major types of taxes individuals pay, including taxes on purchases, property, wealth, and earnings. It explains how the federal income tax is calculated, including determining taxable income, deductions, credits, and the taxes owed. It also reviews strategies for tax planning, preparing and filing tax returns, and what to do if your return is audited. The overall goal is to help people understand their tax obligations while taking advantage of available tax benefits.
Onboarding a new tax representation client involves several key steps: checking for conflicts of interest, obtaining an engagement agreement that defines the scope of work, conducting a tax compliance check using IRS transcripts, helping the client become fully tax compliant, determining if the IRS balance is accurate and reviewing collection alternatives or deficiency resolution options, which may require preparing IRS Form 433 financial statements. The overall goal is to properly define the representation and resolve the client's tax issues.
The document summarizes key aspects of procedures and precedents in U.S. Tax Court. It describes the Tax Court's structure and jurisdiction over tax deficiency cases. It explains procedures for docketing cases, discovery, pre-trial memoranda, and precedent from appeals. The document also covers the small tax case procedure and calendar calls. Finally, it discusses the review process for cases decided by special trial judges.
The document summarizes key aspects of tax administration and planning according to US law. It describes the organizational structure of the Internal Revenue Service (IRS) and its audit processes. It also outlines taxpayer penalties, statutes of limitations, the roles of tax practitioners, and concepts of tax planning to minimize liability legally.
This document provides an overview of installment agreements, which allow taxpayers unable to fully pay their tax bills to pay over time. It discusses what an installment agreement is, the application process, and factors the IRS considers in approving agreements. The IRS may automatically approve agreements for under $10,000 or streamlined agreements up to $50,000. For larger amounts, taxpayers must submit financial information for the IRS to determine their ability to pay based on assets and disposable income. Installment agreements aim to allow taxpayers to pay what they can reasonably afford over time without jeopardizing their livelihoods or earnings.
The document discusses the structure and responsibilities of the Internal Revenue Service (IRS). It covers how Congress creates tax law that the IRS enforces through departments that process tax documents, audit returns, and collect taxes owed. It also summarizes taxpayers' rights and responsibilities in dealing with audits, penalties for noncompliance, and the statute of limitations. Key aspects of tax preparation, tax planning and avoidance of "tax traps" are also addressed.
Ayar law-Delinquent business tax collections MICPAVenar Ayar
Case Study of what the IRS will do and how they will collect your tax dollars owed. When the worst happens call Ayar Law. Don't face your tax problems alone we will help.
The document discusses the IRS's offer in compromise program which allows taxpayers owing back taxes to settle their tax liability for less than the full amount due if they meet certain criteria. Taxpayers can submit offers based on doubt as to liability, doubt as to collectability, or to promote effective tax administration. The IRS will consider factors like the taxpayer's assets, income potential, and special circumstances to determine if an offer should be accepted.
This chapter discusses tax administration and planning. It identifies the organizational structure of the IRS including its departments and service centers. It describes the IRS audit process and outlines penalties for taxpayers and preparers. It discusses statute of limitations, rules for practitioners, and the taxpayer bill of rights. Finally, it provides an overview of basic tax planning concepts.
Can I file my ITR for FY 2020-21 after 31stDecember 2021? What is a belated return? What is the penalty for late filing of return?Till when can I file the belated return?
The document discusses key aspects of the US tax system including:
- Congress creates tax law which the IRS enforces through assessment and collection departments.
- The IRS has authority to audit taxpayers and summon records to examine income and deductions.
- Noncompliance with tax laws results in penalties for issues like filing late, failing to pay taxes owed, or filing a fraudulent return. Statutes of limitation apply.
- Taxpayers have rights that are outlined in publications and when dealing with the IRS regarding audits, appeals and collections.
Application for Settlement of Tax Liabilitytaxman taxman
This document provides instructions and information for taxpayers seeking to settle their tax liability with the Oklahoma Tax Commission through an application for settlement. Key details include:
- Grounds for requesting a settlement include inability to pay resulting in bankruptcy, tax being uncollectible due to insolvency, tax liability attributable to others, or trust fund taxes not collected from customers.
- Eligibility requirements include having a final tax liability, exhausting appeals, being current on filing returns, and not being under bankruptcy or criminal tax investigation.
- To apply, taxpayers must submit an application including financial statements and documentation of collection potential if requesting settlement due to financial hardship.
- The commission will evaluate applications and may request additional information. Accept
The document discusses the key changes made to the TDS/TCS payment, return filing and certificates issuance procedures under the amended rules. Some of the major changes include:
1) Electronic payment of TDS/TCS through Form 17 has become mandatory for all deductors. Unique Transaction Numbers (UTNs) will be issued for each tax payment record.
2) A quarterly TDS/TCS compliance statement in Form 24C must be filed instead of quarterly returns. Annual returns must also be filed by June 15th for all quarters.
3) UTNs must now be quoted on TDS/TCS certificates. Certificates issued for deductions before April 1, 2009 can quote UTNs
The document provides information about tax deducted at source (TDS) in India. Some key points:
1. TDS is a system where specified payments like salary, rent, professional fees etc are subject to tax deduction at source. The tax deducted is remitted to the government and the deductee gets credit for the tax paid.
2. Every deductor must obtain a Tax Deduction Account Number (TAN) to deduct taxes. TDS must be deducted as per prescribed rates depending on the nature of payment.
3. TDS certificates like Form 16 and Form 16A are issued to deductees stating the tax deducted. These can be used for claiming tax credits.
How to check vat registration number (trn) in uaeEddy Mathew
The Tax Registration Number (TRN) is a unique 15-digit number obtained after the VAT registration of a company to differentiate one entity from the other. VAT is an indirect tax imposed on the purchase of goods and services. The implementation of VAT has increased government revenues to improve public welfare in the UAE.
The TRN is a unique 15-digit number that is issued to businesses on VAT registration.
A TRN can enable easy communication between the supplier and purchaser of goods and services while preparing a tax invoice or any other tax-related documents.
Obtaining a TRN can be beneficial for an organization seeking to claim back the tax paid on the purchase of goods and services made by the business while processing the final goods.
A tax registered individual can recover the VAT paid in situations such as:
If VAT is paid for services such as water and electricity for a commercial property, the tax can be refunded.
This document discusses tax evasion, tax avoidance, and tax planning in India. It defines each term and explains the differences between them. Tax evasion is illegal and involves failing to report income or improperly claiming deductions. Tax avoidance uses legal loopholes to reduce tax liability but still defeats the intention of tax laws. Tax planning is the recommended approach, as it involves legitimate strategies like maximizing deductions, investments, and year-end planning to minimize tax burden. The document also outlines some common penalties for tax non-compliance in India.
Accounting provides a standardized language to identify, measure, and communicate a business's economic information. The basic accounting concepts include the chart of accounts (COA), which categorizes transactions into accounts like assets, liabilities, equity, income and expenses. Financial statements like the profit and loss statement, balance sheet, and cash flow statement give an overall picture of the business's performance and financial position using the framework in the COA. Proper accounting helps track cash flows, profits and losses, assets and liabilities to understand a business's whole financial situation.
Canada Revenue Agency's New and Aggressive Tax Enforcement Powers: How You Ca...This account is closed
The document discusses new aggressive tax enforcement powers from the Canada Revenue Agency (CRA). It outlines new whistleblower rewards up to 15% of taxes collected from information provided about major international tax non-compliance. Additional reporting is also required for financial institutions on electronic funds transfers over $10,000 and taxpayers must now report foreign assets over $100,000. The voluntary disclosures program is emphasized as a way for taxpayers to proactively disclose past non-compliance and receive penalty waivers and interest reductions.
This document discusses the difference between tax avoidance and tax evasion. Tax avoidance involves legally minimizing tax liability through legitimate tax planning methods and takes advantage of loopholes in tax laws. It does not involve malintent and carries no public disgrace. Tax evasion, on the other hand, involves illegally avoiding taxes through fraudulent means such as making false statements, omitting information, or not maintaining proper records. Tax evasion is unlawful and punishable under relevant laws. The key differences are that tax avoidance works within legal frameworks while tax evasion uses unfair methods to omit tax liability.
Individual taxpayers who are under audit by the IRS may attend the audit in person without any assistance from a tax professional. However, this can be a dangerous mistake. Although not officially stated, it is the job of an IRS Revenue Agent to conduct an audit with an eye toward finding additional tax owed. With so many gray areas in tax law, and considering the tax code’s complexity, an individual who chooses to go it alone is a sitting duck. With extensive tax education and experience, the examiner can take a position to find additional tax due on the return. Without the necessary knowledge, the taxpayer is powerless to refute the agent’s rationale.
This document provides a step-by-step guide for homeowners to lower their property taxes by appealing their tax assessments. It includes quick start information on filing an appeal, important dates, and an in-depth section explaining key parts of the Texas tax code related to the appeal process. The guide recommends homeowners order an independent appraisal, file an appeal by the May 31st deadline, bring supporting documents to the hearing, and if needed, file an additional appeal and request binding arbitration. It aims to simplify the process which typically takes 4-5 hours spread over the tax year.
This document provides an overview of demand and recovery provisions under India's GST (Goods and Services Tax). It discusses notices issued for tax shortfalls with and without fraud, time limits for these notices, voluntary tax payments, penalties, and orders. It also covers modes of tax recovery if amounts remain unpaid after an order, including deduction from refunds, sale of detained goods/property, and recovery from other parties. Special provisions address void property transfers, tax as the first charge on property, and appeals that result in increased demands.
OBJECTIVE
To understand the steps that need to be followed when a notice is received from the Income Tax Department. To know how to respond to such notices and to understand the practical issues involved in facing such assessments.
Guided by “Sabka Saath, Sabka Vikas, Sabka Vishwas”, the Finance Minister Smt. Nirmala Sitharaman had introduced a new No Dispute but Trust Scheme – ‘Vivad Se Vishwas’ in the Budget 2020 in the Lok Sabha on 5th February, 2020. Expectations are that the new scheme will work better than erstwhile similar scheme “The Direct Tax Dispute Resolution Scheme, 2016”, given the kind of cases that are in appeal.
To know more:https://itatorders.in/blog/eligible-person-under-vivad-se-vishwas-scheme-2020/
Get consultation under the VSV scheme and calculate your taxes : https://www.itatorders.in/vsvcalculator
This document provides information about tax planning and reporting for small businesses. It discusses the various taxes businesses must pay, including federal income tax, self-employment tax, employment taxes, excise tax, sales tax, and local taxes. It describes the common federal tax forms businesses use, such as Form 1040, Schedule C, Form 1120S, Form 941, and Form 1099-MISC. It also discusses state and local tax obligations, paying estimated taxes quarterly, and money management strategies for taxes. The document is a participant guide for a training on tax obligations and planning for small businesses.
Produtos naturais ajudam emagrecer com saudeClinic Mais
O documento discute como produtos naturais como óleo de cártamo, chá verde e fórmula negra podem ajudar no emagrecimento de forma saudável, reduzindo o apetite e estimulando a queima de gordura acumulada, além de terem ações antioxidante e diurética.
El documento define el párrafo como un grupo de oraciones que expresa una idea principal. Explica que un párrafo tiene coherencia y está compuesto por una oración principal y oraciones secundarias. Además, menciona diferentes tipos de párrafos como narrativos, descriptivos y argumentativos. Finalmente, destaca algunas condiciones básicas de un párrafo como la unidad, dinamismo y coherencia.
The document discusses the IRS's offer in compromise program which allows taxpayers owing back taxes to settle their tax liability for less than the full amount due if they meet certain criteria. Taxpayers can submit offers based on doubt as to liability, doubt as to collectability, or to promote effective tax administration. The IRS will consider factors like the taxpayer's assets, income potential, and special circumstances to determine if an offer should be accepted.
This chapter discusses tax administration and planning. It identifies the organizational structure of the IRS including its departments and service centers. It describes the IRS audit process and outlines penalties for taxpayers and preparers. It discusses statute of limitations, rules for practitioners, and the taxpayer bill of rights. Finally, it provides an overview of basic tax planning concepts.
Can I file my ITR for FY 2020-21 after 31stDecember 2021? What is a belated return? What is the penalty for late filing of return?Till when can I file the belated return?
The document discusses key aspects of the US tax system including:
- Congress creates tax law which the IRS enforces through assessment and collection departments.
- The IRS has authority to audit taxpayers and summon records to examine income and deductions.
- Noncompliance with tax laws results in penalties for issues like filing late, failing to pay taxes owed, or filing a fraudulent return. Statutes of limitation apply.
- Taxpayers have rights that are outlined in publications and when dealing with the IRS regarding audits, appeals and collections.
Application for Settlement of Tax Liabilitytaxman taxman
This document provides instructions and information for taxpayers seeking to settle their tax liability with the Oklahoma Tax Commission through an application for settlement. Key details include:
- Grounds for requesting a settlement include inability to pay resulting in bankruptcy, tax being uncollectible due to insolvency, tax liability attributable to others, or trust fund taxes not collected from customers.
- Eligibility requirements include having a final tax liability, exhausting appeals, being current on filing returns, and not being under bankruptcy or criminal tax investigation.
- To apply, taxpayers must submit an application including financial statements and documentation of collection potential if requesting settlement due to financial hardship.
- The commission will evaluate applications and may request additional information. Accept
The document discusses the key changes made to the TDS/TCS payment, return filing and certificates issuance procedures under the amended rules. Some of the major changes include:
1) Electronic payment of TDS/TCS through Form 17 has become mandatory for all deductors. Unique Transaction Numbers (UTNs) will be issued for each tax payment record.
2) A quarterly TDS/TCS compliance statement in Form 24C must be filed instead of quarterly returns. Annual returns must also be filed by June 15th for all quarters.
3) UTNs must now be quoted on TDS/TCS certificates. Certificates issued for deductions before April 1, 2009 can quote UTNs
The document provides information about tax deducted at source (TDS) in India. Some key points:
1. TDS is a system where specified payments like salary, rent, professional fees etc are subject to tax deduction at source. The tax deducted is remitted to the government and the deductee gets credit for the tax paid.
2. Every deductor must obtain a Tax Deduction Account Number (TAN) to deduct taxes. TDS must be deducted as per prescribed rates depending on the nature of payment.
3. TDS certificates like Form 16 and Form 16A are issued to deductees stating the tax deducted. These can be used for claiming tax credits.
How to check vat registration number (trn) in uaeEddy Mathew
The Tax Registration Number (TRN) is a unique 15-digit number obtained after the VAT registration of a company to differentiate one entity from the other. VAT is an indirect tax imposed on the purchase of goods and services. The implementation of VAT has increased government revenues to improve public welfare in the UAE.
The TRN is a unique 15-digit number that is issued to businesses on VAT registration.
A TRN can enable easy communication between the supplier and purchaser of goods and services while preparing a tax invoice or any other tax-related documents.
Obtaining a TRN can be beneficial for an organization seeking to claim back the tax paid on the purchase of goods and services made by the business while processing the final goods.
A tax registered individual can recover the VAT paid in situations such as:
If VAT is paid for services such as water and electricity for a commercial property, the tax can be refunded.
This document discusses tax evasion, tax avoidance, and tax planning in India. It defines each term and explains the differences between them. Tax evasion is illegal and involves failing to report income or improperly claiming deductions. Tax avoidance uses legal loopholes to reduce tax liability but still defeats the intention of tax laws. Tax planning is the recommended approach, as it involves legitimate strategies like maximizing deductions, investments, and year-end planning to minimize tax burden. The document also outlines some common penalties for tax non-compliance in India.
Accounting provides a standardized language to identify, measure, and communicate a business's economic information. The basic accounting concepts include the chart of accounts (COA), which categorizes transactions into accounts like assets, liabilities, equity, income and expenses. Financial statements like the profit and loss statement, balance sheet, and cash flow statement give an overall picture of the business's performance and financial position using the framework in the COA. Proper accounting helps track cash flows, profits and losses, assets and liabilities to understand a business's whole financial situation.
Canada Revenue Agency's New and Aggressive Tax Enforcement Powers: How You Ca...This account is closed
The document discusses new aggressive tax enforcement powers from the Canada Revenue Agency (CRA). It outlines new whistleblower rewards up to 15% of taxes collected from information provided about major international tax non-compliance. Additional reporting is also required for financial institutions on electronic funds transfers over $10,000 and taxpayers must now report foreign assets over $100,000. The voluntary disclosures program is emphasized as a way for taxpayers to proactively disclose past non-compliance and receive penalty waivers and interest reductions.
This document discusses the difference between tax avoidance and tax evasion. Tax avoidance involves legally minimizing tax liability through legitimate tax planning methods and takes advantage of loopholes in tax laws. It does not involve malintent and carries no public disgrace. Tax evasion, on the other hand, involves illegally avoiding taxes through fraudulent means such as making false statements, omitting information, or not maintaining proper records. Tax evasion is unlawful and punishable under relevant laws. The key differences are that tax avoidance works within legal frameworks while tax evasion uses unfair methods to omit tax liability.
Individual taxpayers who are under audit by the IRS may attend the audit in person without any assistance from a tax professional. However, this can be a dangerous mistake. Although not officially stated, it is the job of an IRS Revenue Agent to conduct an audit with an eye toward finding additional tax owed. With so many gray areas in tax law, and considering the tax code’s complexity, an individual who chooses to go it alone is a sitting duck. With extensive tax education and experience, the examiner can take a position to find additional tax due on the return. Without the necessary knowledge, the taxpayer is powerless to refute the agent’s rationale.
This document provides a step-by-step guide for homeowners to lower their property taxes by appealing their tax assessments. It includes quick start information on filing an appeal, important dates, and an in-depth section explaining key parts of the Texas tax code related to the appeal process. The guide recommends homeowners order an independent appraisal, file an appeal by the May 31st deadline, bring supporting documents to the hearing, and if needed, file an additional appeal and request binding arbitration. It aims to simplify the process which typically takes 4-5 hours spread over the tax year.
This document provides an overview of demand and recovery provisions under India's GST (Goods and Services Tax). It discusses notices issued for tax shortfalls with and without fraud, time limits for these notices, voluntary tax payments, penalties, and orders. It also covers modes of tax recovery if amounts remain unpaid after an order, including deduction from refunds, sale of detained goods/property, and recovery from other parties. Special provisions address void property transfers, tax as the first charge on property, and appeals that result in increased demands.
OBJECTIVE
To understand the steps that need to be followed when a notice is received from the Income Tax Department. To know how to respond to such notices and to understand the practical issues involved in facing such assessments.
Guided by “Sabka Saath, Sabka Vikas, Sabka Vishwas”, the Finance Minister Smt. Nirmala Sitharaman had introduced a new No Dispute but Trust Scheme – ‘Vivad Se Vishwas’ in the Budget 2020 in the Lok Sabha on 5th February, 2020. Expectations are that the new scheme will work better than erstwhile similar scheme “The Direct Tax Dispute Resolution Scheme, 2016”, given the kind of cases that are in appeal.
To know more:https://itatorders.in/blog/eligible-person-under-vivad-se-vishwas-scheme-2020/
Get consultation under the VSV scheme and calculate your taxes : https://www.itatorders.in/vsvcalculator
This document provides information about tax planning and reporting for small businesses. It discusses the various taxes businesses must pay, including federal income tax, self-employment tax, employment taxes, excise tax, sales tax, and local taxes. It describes the common federal tax forms businesses use, such as Form 1040, Schedule C, Form 1120S, Form 941, and Form 1099-MISC. It also discusses state and local tax obligations, paying estimated taxes quarterly, and money management strategies for taxes. The document is a participant guide for a training on tax obligations and planning for small businesses.
Produtos naturais ajudam emagrecer com saudeClinic Mais
O documento discute como produtos naturais como óleo de cártamo, chá verde e fórmula negra podem ajudar no emagrecimento de forma saudável, reduzindo o apetite e estimulando a queima de gordura acumulada, além de terem ações antioxidante e diurética.
El documento define el párrafo como un grupo de oraciones que expresa una idea principal. Explica que un párrafo tiene coherencia y está compuesto por una oración principal y oraciones secundarias. Además, menciona diferentes tipos de párrafos como narrativos, descriptivos y argumentativos. Finalmente, destaca algunas condiciones básicas de un párrafo como la unidad, dinamismo y coherencia.
This document discusses an investigation into optimizing the crystallization of a novel cellulase enzyme from Daphnia pulex (DpGH7) using x-ray crystallography. It provides background on the need for renewable biofuels and challenges with converting cellulosic biomass. Temperature manipulation and crystal seeding techniques are explored to improve DpGH7 crystal growth for structural determination. The document reviews literature on novel cellulases from marine organisms and the potential of DpGH7 compared to a salt-tolerant enzyme from Limnoria quadripunctata.
El documento ofrece los servicios de una cooperativa peruana llamada "Santo Domingo" que se especializa en la intermediación laboral, administración de nóminas, tercerización de procesos, selección y capacitación de personal. La cooperativa tiene más de 25 años de experiencia brindando soluciones integrales en gestión de recursos humanos a empresas nacionales y extranjeras.
La salud pública en Venezuela enfrenta graves desafíos. El sistema de salud pública sufre de escasez de medicamentos y suministros médicos básicos, así como de infraestructura y personal médico inadecuados. La hiperinflación y la crisis económica han empeorado drásticamente la capacidad del gobierno para proporcionar atención médica básica a los ciudadanos venezolanos.
Este documento presenta un resumen del primer trabajo práctico de informática realizado por los alumnos Martín Mendoza y Delfina Rey para la asignatura Tecnología Informática en el año 2013. Incluye la historia de la informática desde los orígenes hasta la quinta generación de computadoras, conceptos básicos sobre hardware, software, periféricos y sistemas operativos.
La Hermandad de la Esperanza de Triana se fundó en 1418 en Sevilla. Procesiona con dos pasos principales, el Stmo. Cristo de las Tres Caídas y Nuestra Señora de la Esperanza bajo palio. La cofradía cuenta con varias insignias y detalles artísticos en plata y bordados, y sus nazarenos visten túnicas moradas y blancas. También tiene una capilla histórica en el estilo arquitectónico sevillano.
Fong Cha completed a certificate course in administering Microsoft Exchange Server 2016 through online learning from New Horizons Computer Learning Center on August 12, 2016. The certificate was presented by Jessica Tutewohl, Operations Coordinator at New Horizons Computer Learning Center, to acknowledge Fong Cha's successful completion of the course.
This certificate from All Events in City certifies that Ms. Tannu Agarwal completed a 3-month internship in digital marketing from November 1, 2015 to December 31, 2015 under the guidance of Amit Panchal. During her internship, her performance was excellent and she was hardworking. The certificate recommends giving her the maximum score if any academic evaluation is involved.
La netiqueta se refiere al conjunto de reglas que regulan el comportamiento de los usuarios en foros, grupos de noticias y correo electrónico. Al unirse a un foro, es importante leer los mensajes de los demás antes de enviar los propios y siempre citar las fuentes para evitar violar derechos de autor. Las reglas de cortesía como saludar, pedir cosas por favor y dar las gracias son apreciadas. El asunto del mensaje debe ser específico para no ser ignorado.
Our Pumpkin Carving Safety Infographic is the perfect guide to follow for a safe and enjoyable Halloween. We outline some of our top Halloween safety tips to follow to ensure that you have a safe holiday and share a pumpkin carving guide that will help you carve the perfect pumpkin. We share a roasted pumpkin seed recipe that will have the whole family asking for more.
Por medio del cual se prohíbe el parqueo de vehículos automotores en el Centro Histórico, y otras zonas del municipio, se reglamenta la peatonalización del Centro histórico y otras zonas del municipio, se reglamenta la utilización del espacio público de Santa Fe de Antioquia, y se dictan otras disposiciones.
Este documento presenta la introducción al Programa Nacional de Formación en Informática (PNFI) del Instituto Universitario de Tecnología de Bolívar (IUTEB). Explica la fundamentación, vinculaciones y retos del PNFI, así como su filosofía de software libre. También describe el diseño curricular con sus cuatro trayectos, la administración del modelo, los procesos de inserción y aspectos estudiantiles. Finalmente, presenta al personal docente del PNFI en el IUTEB.
El documento describe el movimiento romántico en literatura. Señala que surgió a finales del siglo XVIII en Inglaterra y Alemania, y se caracterizó por el liberalismo, individualismo, subjetivismo e imaginación. Aborda los principales temas románticos como la naturaleza, evasión y libertad individual, así como los géneros literarios y autores más representativos como Espronceda, Bécquer, Rosalía de Castro y Larra.
The document discusses various interior design projects including house floor plans, multipurpose room design, living room design, kitchen design, furniture selection, line drawings, renderings, and restaurant redesigns. A variety of interior design techniques are shown such as pencil sketches, 3D models, furniture exhibitions, and before and after images of restaurant design projects.
Alphorm.com support de la formation programmer en C# 6Alphorm
Formation complète ici :
http://www.alphorm.com/tutoriel/formation-en-ligne-programmer-en-csharp-6
Suite à la formation de découverte Programmer en C# avec Visual Studio 2015 traitant en douceur la programmation en C#. Béchir BEJAOUI, formateur certifié Microsoft, vous a préparé cette formation C# 6 qui vous permettra de maîtriser de se perfectionner sur le C# et profiter du retour de l’expérience du Béchir via plusieurs études de cas soigneusement choisis et exposés.
Pendant cette formation C# 6, vous allez comprendre l’évolution des Framework .NET depuis 2.0 jusqu’à la version 6.0. Les grands changements à chaque nouvelle version seront détaillés avec des démonstrations orientées pratiques. Aussi le Scriptcs vous sera bien expliqué avec un exemple guidé pour vous aider à exécuter vos programmes sous Linux.
Ensuite durant cette formation C# 6, vous allez pouvoir maitriser le .Net Core, le compilateur ROSLYN et le cloud avec C#6.
Cette formation C# 6 se terminera par 10 études de cas sur différentes problématiques et leurs solutions sous C # 6.
El resumen del documento es:
1) El informe describe las actividades realizadas por el pasante José Gabriel Rodrigues Ferreira durante sus tres meses de pasantía en la empresa Kuehne + Nagel, S.A.
2) Como parte de la pasantía, el pasante participó en procesos de valoración de mercancías, operaciones logísticas, y atención al cliente para importaciones y exportaciones.
3) El pasante también realizó estudios de casos prácticos que involucraron la importación de medicamentos y el cumplimiento de permisos
El documento describe el cyberbullying como el uso de medios electrónicos como correos, redes sociales y teléfonos para acosar a individuos o grupos. Explica que las redes sociales promueven y permiten el cyberbullying. También detalla que los jóvenes afectados pueden sentirse menos valorados, tener baja autoestima e incluso llegar al suicidio en casos extremos. Finalmente, propone tres estrategias para prevenir el cyberbullying: no hacer caso a los mensajes, comunicarse con alguien para resolver el problema y bloquear al
The document provides an overview of collection due process (CDP) procedures that taxpayers can use to dispute tax liens and levies issued by the IRS. It discusses how taxpayers can request a CDP hearing after receiving a notice of tax lien or intent to levy. It also outlines the issues that can be raised in a CDP hearing, such as challenges to the collection action or underlying liability. The document notes that taxpayers have the right to judicial review of adverse determinations from CDP hearings. It also discusses penalties for frivolous or dilatory CDP requests.
This document provides an overview of dealing with the IRS, with a focus on collections. It discusses the different levels of authority within the IRS and representation levels for tax professionals. The key steps in the collections process are outlined, including options for installment agreements, penalty abatement, offers in compromise, and appealing enforcement actions. Collection alternatives like liens, levies and seizures are also summarized.
Learn about the fundamentals of the IRS’ collection appeals program as well as the practical knowledge and skills needed by Circular 230 practitioners working collection cases involving appeals. This presentation includes information on the Collection Due Process (CDP) and Collection Appeals (CAP) programs, including how to initiate each, appropriate timing and use, as well as what should be accomplished in the course of each appeal. You'll also be able to read about CDP and CAP’s limitations in addition to other appeal programs.
The IRS on June 10, 2014 published a Taxpayer Bill of Rights document. The document include 10 rights you have as a taxpayer. The IRS says this document will be "sent to millions of taxpayers this year when they receive IRS notices on issues ranging from audits to collection. The rights will also be publicly visible in all IRS facilities for taxpayers and employees to see."
Workshop on Understanding the Amended law of Service Tax dated 03.09.2014 Ses...Agarwal sanjiv & Co
This document summarizes information about enquiries, audits, and show cause notices in service tax. It discusses who can initiate enquiries, what to do if enquired, and potential outcomes which include further investigation, departmental audit, special audit, or issuance of a show cause notice. The document also covers summons, describing them as a tool to conduct enquiries when taxpayers do not cooperate. It provides guidance on how to properly handle a summons.
The document outlines the anatomy of a civil tax controversy process between a taxpayer and the IRS. It discusses the following key steps:
1. The IRS conducts a tax audit to ensure accurate tax reporting. All tax returns are subject to audit.
2. If the audit finds a deficiency, the taxpayer receives a "30-day letter" and can request an appeals conference or do nothing.
3. If no agreement is reached in appeals or the taxpayer ignores the letter, a "90-day letter" is sent requiring payment or a tax court petition within 90 days.
4. If the taxpayer petitions tax court, the case may be settled or proceed to trial and potential appeals. If not,
Workshop on Understanding the Amended law of Service Tax dated 29.08.2014 Se...Agarwal sanjiv & Co
This document summarizes information presented in a workshop on service tax laws and procedures in India. It discusses the processes of enquiries, summons, audits, and show cause notices that the tax authorities can initiate. It provides details on who can conduct enquiries and audits, how taxpayers should respond to summons, and the potential outcomes of these actions, which include further investigation, issuance of show cause notices, searches and seizures, and prosecution.
FOLLOWER NOTICES AND ACCELERATED PAYMENTSRobert Maas
This document provides information about accelerated payment notices (APNs) and follower notices issued by HMRC. It summarizes that APNs require taxpayers to pay disputed taxes upfront if they have an open enquiry or appeal, and outlines the objection grounds and payment deadlines. Follower notices request amendment of tax returns based on similar cases, with potential penalties for noncompliance. The document advises taxpayers on issues like payment options and settlement opportunities.
Slide (09.03.18)_Know the process Know your RightsMiew Kwan Lee
This document discusses topics related to tax audits and investigations, including:
1) It outlines common trigger factors that raise red flags for the tax authority such as inconsistent profits or deductions, related party transactions, and cash transactions.
2) It explains the difference between tax evasion, which is illegal, and tax avoidance, which uses legal methods to reduce taxes paid.
3) It provides examples of expenses that may be disallowed like personal expenses claimed as business expenses and issues with foreign worker documentation.
Receiving a notice from the Internal Revenue Service is
usually no cause for alarm. Every year the IRS sends millions
of letters and notices to taxpayers. In the event one
shows up in your mailbox, here are ten things you should
know.
Receiving a notice from the Internal Revenue Service is
usually no cause for alarm. Every year the IRS sends millions
of letters and notices to taxpayers. In the event one
shows up in your mailbox, here are ten things you should
know.
Workshop on Understanding the Amended law of Service Tax dated 03.09.2014 Ses...Agarwal sanjiv & Co
This document summarizes the key aspects of the adjudication process for service tax demands in India. It discusses the triggers for issuance of a show cause notice, the contents and timing of show cause notices, the handling and adjudication of show cause notices, and the consequences after an adjudication order is issued. The presentation covers the demand determination process, principles of natural justice that must be followed, requirements for a valid adjudication order, and jurisdictional limits for different tax officers to adjudicate cases involving certain demand amounts.
This document discusses how to prepare for an IRS audit. It outlines the different types of audits, including mail-in, office, and field audits. It describes the audit process, including initial contact, information document requests, and the anatomy of an income tax audit. Key areas the IRS will examine include revenues, employee compensation, outside contractors, travel and meals, office expenses, and miscellaneous expenses. The document emphasizes being organized, only providing what is requested, and hoping for a "no change letter" at the end of the audit.
This document discusses tax practice and ethics regarding Campbell Corporation's tax return preparation. Campbell develops electronic products including GPS applications. Its research department works with the US government and on software development. Some research qualifies for the federal tax credit but some items are uncertain. As Campbell's tax advisor, you must determine how aggressive to be in claiming credits, consider potential penalties, and provide diligent advice given limited expertise in GPS software. The document then summarizes IRS administration including letter rulings, determination letters, technical advice memorandums, audit selection processes, audit types and procedures.
This document discusses common TDS violations found during surveys conducted by the Income Tax Department. It outlines several types of common violations:
1) Non-deposition of taxes deducted, which is often seen in struggling businesses.
2) Failure to apply the normal deduction rates, as seen in an insurance business.
3) Failure to make any TDS deductions for a TPA (third party administrator) business.
4) Not treating non-refundable rent advances as attracting TDS under section 194I.
5) Misclassifying professional fees paid to guest lecturers as salary.
The document provides guidance on purpose, selection, operation, and procedures for conducting TDS surveys
This presentation covered the following:
-ATO audits and reviews
-Tips on dealing with the ATO
-The true power of the ATO
-What comes after the notice of assessment, from objecting to the tax assessment, to debt recovery proceedings from the ATO
IRS, DOL (and PBGC) Audits and Other MattersHarvey Katz
The document discusses insights from a practitioner on IRS audits of retirement plans. It provides an overview of the audit process, from initial selection and document requests to closing procedures. Key points include tailoring responses based on the perceived audit focus, limiting direct document production to the IRS, and identifying errors upfront to facilitate correction. The goal is to minimize further investigations or financial consequences through a rigorous yet measured response.
The document provides information on VAT registration in the UAE, including:
- Who is required to register, with mandatory registration threshold of AED 375,000 in annual supplies.
- How to calculate turnover for registration, including taxable supplies.
- The process for registering online via the FTA portal, including completing the registration form.
- Record keeping requirements for VAT registered entities.
- Penalties for non-compliance and tax evasion.
- The FTA's ability to conduct audits of businesses to ensure accurate tax reporting.
A Complete Guide to Handling CRA Tax AssessmentsSAU Consulting
Navigating CRA tax assessments requires a thorough understanding of the process, potential triggers, and available recourse options. By staying informed and proactive, taxpayers can effectively manage their tax obligations and address any issues that may arise during the assessment process. Understanding the process and implications of CRA tax assessments is essential for individuals and businesses alike. Here's a comprehensive guide to navigating CRA tax assessments. For more, visit us at https://www.sauconsulting.ca/our-services/taxdisputes
3. HELPFUL HINTS – AUDIT NOTICE
• Don’t Ignore
• Read closely
• Don’t assume the
worst
• Don’t assume proper
request – Look for
Templates
• Look for deadlines
• Call if questions
• Know your TP rights*
• Keep copies
• Never send your
originals
• IRS never emails –
Watch Scams
3T
4. TAXPAYERS’ RIGHTS
1. The Right to Be Informed: Taxpayers have the right to know what they
need to do to comply with the tax laws. They are entitled to clear explanations
of the laws and IRS procedures in all tax forms, instructions, publications,
notices, and correspondence. They have the right to be informed of IRS
decisions about their tax accounts and to receive clear explanations of the
outcomes.
2. The Right to Quality Service: Taxpayers have the right to receive prompt,
courteous, and professional assistance in their dealings with the IRS, to be
spoken to in a way they can easily understand, to receive clear and easily
understandable communications from the IRS, and to speak to a supervisor
about inadequate service.
3. The Right to Pay No More than the Correct Amount of Tax: Taxpayers
have the right to pay only the amount of tax legally due, including interest and
penalties, and to have the IRS apply all tax payments properly.
4
D
5. TAXPAYERS’ RIGHTS (CONT)
4. The Right to Challenge the IRS’s Position and Be Heard:
Taxpayers have the right to raise objections and provide additional
documentation in response to formal IRS actions or proposed actions,
to expect that the IRS will consider their timely objections and
documentation promptly and fairly, and to receive a response if the IRS
does not agree with their position.
5. The Right to Appeal an IRS Decision in an Independent Forum:
Taxpayers are entitled to a fair and impartial administrative appeal of
most IRS decisions, including many penalties, and have the right to
receive a written response regarding the Office of Appeals’ decision.
Taxpayers generally have the right to take their cases to court.
5
D
6. TAXPAYERS’ RIGHTS (CONT)
6. The Right to Finality: Taxpayers have the right to know the maximum
amount of time they have to challenge the IRS’s position as well as the
maximum amount of time the IRS has to audit a particular tax year or
collect a tax debt. Taxpayers have the right to know when the IRS has
finished an audit.
7. The Right to Privacy: Taxpayers have the right to expect that any IRS
inquiry, examination, or enforcement action will comply with the law and
be no more intrusive than necessary, and will respect all due process
rights, including search and seizure protections and will provide, where
applicable, a collection due process hearing.
8. The Right to Confidentiality: Taxpayers have the right to expect that
any information they provide to the IRS will not be disclosed unless
authorized by the taxpayer or by law. Taxpayers have the right to expect
appropriate action will be taken against employees, return preparers, and
others who wrongfully use or disclose taxpayer return information.
6
D
7. TAXPAYERS’ RIGHTS (CONT)
9. The Right to Retain Representation: Taxpayers have the right to retain an
authorized representative of their choice to represent them in their dealings
with the IRS. Taxpayers have the right to seek assistance from a Low Income
Taxpayer Clinic if they cannot afford representation.
10. The Right to a Fair and Just Tax System: Taxpayers have the right to
expect the tax system to consider facts and circumstances that might affect
their underlying liabilities, ability to pay, or ability to provide information timely.
Taxpayers have the right to receive assistance from the Taxpayer Advocate
Service if they are experiencing financial difficulty or if the IRS has not resolved
their tax issues properly and timely through its normal channels.
7
D
13. POLLING QUESTION #2
Have you ever used the services described in the
previous slides?
1 – Yes
2 - No
13
14. CONTACTING IRS BY PHONE
• Note (Document)
• Date/time
• Agent’s name
• Badge number
• Summary
• Before ending call
• Set expectations
• TP and IRS
• Note deadlines
• IRS does!
• Typical Phone Issues
• Refund inquiries (web*)
• Return items
• Missing payments
• Status of return
• Amended (web*)
• Transcripts (web*)
• CP 2000 matching
• Math errors
• First-time abatement
14
T
15. BE PREPARED BEFORE CONTACT
Know Facts
• Interview TP
• Obtain Transcripts
• Review returns at Issue
• Research the law/cases/rulings
Document all contacts with taxing authority
• Date/time
• Agent’s name and ID
• Issues discussed
• Outcomes
• Follow-up: For IRS and For TP (include timing)
15
T
16. BE PREPARED B/F CONTACT (CONT)
• POA(Form 2848 ) or Tax Info Auth(Form 8821)
• 8821: Information gathering/Not for representation
• 2848: Represent TP before all offices of the IRS
• Returns
• Notices
• Cancelled Checks
• All tax IDs
• Fax Machines (RightFax) – IRS has this now!
• Good way to document communications with IRS.
• Get the TP current – Tax Filings/Estimated Payments
16
D
17. BE PREPARED B/F CONTACT (CONT)
Statute of Limitations Analysis - Obtain transcripts
• For Assessment (Assessment done before collection)
• 3 Years from original due date or filing (later of the 2)
• Extended to 6 years – 25%+ omitted gross income
• No statute for non-filers or fraudulent returns
• For non-filers 6 years of returns + current often works
• All PR returns statute starts on the 4/15, after filing.
• Collections
• 10 years from date of assessment
• Watch tolling events – Bankruptcy proceedings, OIC pending or
CDP hearing
• Refunds
• 3 years from filing of return or 2 years from payment (later of the 2)
17
D
18. BE PREPARED B/F CONTACT (CONT)
If on the Phone:
• Headset
• Easy Access to move around
• Readily available Fax
• Comfortable chair
• Other productive work
Helpful to know potential options available
• Liability: Reasonable Cause, FTA, misapplication of law
• Collections: PPIA, IA, OIC, CNC
18
D
19. BE PREPARED B/F CONTACT (CONT)
When Corresponding, include….
• TP Name and FID (On all pages)
• Tax Year
• Type of Tax
• Copy of Notice
• Form 2848 or Form 8821
• Well Indexed Supporting Documentation
19
D
20. IRS LEVELS OF AUTHORITY
• ACS
• Tax Examiners
• TCO
• RA (A for Audit)
• RO (O for Owes)
• Offer Specialists
• Taxpayer Advocates
• Appeals Officer (E)/Settlement Officer (C)
• Manager
• Group
• Territory
20
D
21. REP LEVEL OF AUTHORITY
• Providing info to IRS (one-way only)
• Anyone
• Obtaining info from IRS
• Need 8821 (anyone can use)
• Exam representation – 2848 POA
• Enrolled: CPA/EA/JD
• Others: Unenrolled preparer, company employee (limited)
• Collection representation – 2848
• Must be enrolled
• POA can sign a 8821 for a TP
• Can send 2848/8821 to agent, then fax to CAF
21
T
WatchBy-pass
23. 23
CAF Units
IRS Practitioner Hotline
866-860-4259
Handle up to 3 cases/Call
Must be Ind or Biz, no mixing
Better to call IRS, then write
Ask for ASED, CSED. TP Right
#6
24. CP 2000 NOTICE – MATCHING
AUTOMATED UNDER REPORTER (AUR)
• Matches Return with info IRS receives – 3rd Party
• Shows Adjustment, Propose Tax or Refund
• Not a bill at this point
• Watch date. Normally, 30 days response
• Review very carefully
• If you agree, do not amend return, just let IRS know
• If you disagree, don’t sign notice
• Explain on writing why you disagree
• Attach copy of all documentation support
• Attach copy of notice
• Watch for Deadlines!
• Unopened envelopes still count! 24
T
25. 30 DAY LETTER_STAT NOTICE
Must meet deadlines to preserve rights to:
• Appeals (30-Day Letter)
• 30 days from date on letter (extendable)
• If less than 6 months left on statute of limitation, may go right to
stat notice (see below)
• Not dictated by statute so extension to respond is available
• Tax Court (Statutory Notice of Deficiency)
• 90 dates from date on letter (not extendable)
• If you haven’t been to appeals, referred to there first.
• If you’ve been to appeals, you can request meeting with IRS chief
counsel’s office.
If these are missed, case moves to Collection.
25
T
26. AUDIT DIVISION
• 3 Methods of Assessment
• Self Assessment (Return filing)
• Deficiency (Upon audit or examination)
• Jeopardy/Termination (Ability to assess or collect is in danger)
• Jeopardy – For years that have ended.
• Termination – For years not ended - Tax year deemed completed
• Assessment
• Needed for Collection Purposes
• Required starting point for collection
26
D
27. AUDIT DIVISION(CONT)
• Types - Field/Office/Correspondence/CP 2000/TCMP
• Deal with a TCO (Office) or RA (Field)
• Deal with tax examiners on a Correspondence Audit
• At a minimum inquire about the following:
• Ask why being Audited
• Ask for Managerial contact Info
• Ask about any 3rd Party Contact (Pub 1)
• Agree or Disagree with Outcome
• Disagree: Speak to agent and/or supervisor
• If still disagree: Petition Appeals (30 day letter)
• If not satisfied with appeals, 2 alternatives
• Petition Tax Court (90 day or Stat Notice) – Not Extendable
• Pay Tax, sue in District or Claims Court
27
D
28. AUDIT DIVISION(CONT)
Third-Party Contact
• Ask who they are or will be going to.
• Request:
• Summary of Discussions – Ltr 3172
• 3rd Party Contact notes – Likely will need a FOIA request
• For any that haven’t happened yet
• Address contact that might be detrimental or deemed harassment.
• See if you can provide info that Agent is looking for.
28
D
30. AUDIT DIVISION(CONT)
IRS Exam and Technique Guides
Industry specific guides – ATG
30
D
The IRM and ATG provide guidance. IRS personnel, by policy,
must follow. For Practitioners, they are guidance only. Don’t
assume that they synch with Law or Regulations.
31. AUDIT DIVISION(CONT)
• Appeals Petition (to 30 day letter)
• Background - New AJAC procedures – More Judicial in nature
• Request Face-to-Face Meeting (Make sure you’re prepared!)
• Develop the Facts
• Discussion of Applicable Law
• Propose Solution, then Conclusion
• Watch All Expiration Dates! If based on Notice, use TP’s
• Request Auditor’s WP to prepare for Appeals
• Ask Auditor. They are suppose to give it to you. IRC 6013(e)
• If Auditor not forthcoming
• Submit FOIA Request to IRS In Writing to IRS Disclosure Office
• http://www.irs.gov/uac/IRS-Disclosure-Offices
• CC: Auditor’s Manager
• Mention your request to auditor.
• Mention in the FOIA request that you asked the auditor
31
D
32. AUDIT DIVISION(CONT)
Extending the Statute of Limitations(Don’t take lightly)
Your rights:
• Refuse
• Limit to particular issues
• Limit the extension to a particular period (Keep to 6 mos)
Criminal Investigation Division (CID) Contact
• Always request to know:
• Target
• Subject
• Person of Interest
• Request a “friendly” summons if POI.
• Tread light. Seek counsel, if appropriate – Target/Subject
32
D
33. AUDIT DIVISION(CONT)
Reason for Audits
• CP 2000 – Matching
• Inter – jurisdiction Exchange
• National Research Program (NRP)
• Taxpayer Compliance Measurement Program (TCMP)
• Discriminate Function System (DIF Scores)
• Related or Associated TPs
• Public Records
• Non-filer Information
• Whistleblower (normally compensated w/some %)
Watch for the “F” word
• Once suspected, STOP, Contact a Tax Atty.
• For Non-Atty, no privilege exist in a criminal case.
• Could use Kovel
• Avoid using Preparer of returns. Use “Dummy”
33
D
34. AUDIT DIVISION(CONT)
Eggshell Audits – Civil potentially going Criminal
• Objectives of Practitioners
• Keeping exam civil v. criminal - Primary!
• Preserving Privilege under Kovel (Avoid Preparer)
• Dealing with civil fraud penalty
• TP compliance
• Questioning (Perjury)
• Summons
• Self-incrimination (5th Amendment)
• Badges of Fraud
• Service’s attempt to overcome Tweel case
• Fraud Technical Advisor
• Revenue Agents go “Black”
34
D
35. AUDIT DIVISION(CONT)
No Records Audits
• Cohan Rule
• Not for T&E or Gifts
• Reconstruct
• Estimate
• Obtain IRS transcripts
• Contact Vendors
• Obtain Bank statements/Employers
• Affidavits
35
D
36. WHAT IF YOU GET A SUMMONS?
FORM 2039
36
• Nothing in the IRC giving IRS power to enforce.
• DOJ attorney involvement needed – District Court.
• Requirement to enforce summons -- Powell.
• Powell Criteria (All 4 must be met)
• Investigation much be legitimate.
• Information sought must be relevant.
• IRS must not already possess.
• All administrative steps must have been exhausted.
• Like notices, do not ignore.
• Consult with legal counsel, if necessary.
37. WHAT IF YOU GET A SUMMONS?
FORM 2039 (CONT)
37
38. AUDIT PREPARATION
• Review IRM Part 4 – Examining Process (Particularly IRM 4.10)
• Interview taxpayer
• Familiarize yourself with business
• Explain audit process to taxpayer
• Outline expectation you have with respect to taxpayer
• Minimum that TP should bring
• Copy of returns
• All IRS correspondence
• If you accept engagement
• Engagement letter - Note scope and year(s) covered
• Cover appeals?
• Cover collections?
• Fees
• Retainer
• POA
• Technically, you must know your stuff
• Exam Process
• Tax Issues 38
39. AUDIT PREPARATION(CONT)
• Review Return for Sensitive Issues
• T&E
• Auto
• Deferred Income
• Accrued Wages/Commission/Salaries
• Reconcile Bank Deposits to Gross Revenues
• Look at Related Companies (Similar issues, I/C Accounts)
• Contact Auditor
• Ascertain reason for audit selection
• Narrow down issue(s)
• Get name/number of their boss
• Arrange business tour/Summary of TP business
• Set up off-site field location for auditor
• Select date/time that will allow TP time to properly prepare
• Possible discussion on unintentional return inaccuracies.
39
40. CONDUCT OF THE AUDIT
Conducting the Audit
Location outside of place of business
Restrict discussions to lead person on the case
Make sure key issues are well documented
Provide requested documents in orderly manner
Make sure request on IDRs are proper. Watch for template
requests.
Provide only what is requested, never volunteer information unless
doing so is favorable
Don’t have to advocate for the Service
For unclear or broad request, don’t guess
Watch for deadlines in providing information
40
41. CONDUCT OF THE AUDIT(CONT)
Conducting the Audit
Maintain a “copies” folder or log
Segregate any documents where asserting privilege
Set up separate folder marked – “Protected under IRC 7525”
Prior to Audit Meeting
Ask TP about privileged information
TP is only one who can designate as privilege
Advocate aggressively, but remember….
Creditability and integrity are your greatest assets.
Request ECD – Estimated Completion Dates
Adopt a style that works for you
Anything you provide to Agent becomes “record” 41
42. CONDUCT OF THE AUDIT(CONT)
Privilege Log
If you create a privilege file under IRC 7525, a log should
be maintained and provided to Service, when requested:
• Date privilege asserted
• Type document
• Author(s)
• Recipient(s)
• General Subject Matter of Document
• Privilege claimed (Federal tax practitioner privilege under
IRC 7525) Caution: only for Non-Criminal
42
43. CONDUCT OF THE AUDIT(CONT)
Contact with Auditor
• Emphasis with TP and agent
• No contact between 2 without reps knowledge
• Keep in mind --- Agent is trained investigator
• Agent would like nothing better than dialogue w/TP
• Make sure Rep CC’s on correspondence
• Tell client to send all correspondence to Rep
• If By-Pass letter issue – address and appeal
• As a Rep, watch for too broad of question
• i.e. Any wrong doing here?
• Always argue penalties
43
44. CONDUCT OF THE AUDIT(CONT)
Contact with Auditor
• First meeting
• Always ask for ID - Make sure they are not CI.
• Especially if you have 2 of them
• Ask what issues caused the audit
• Before audit
• Systems identifies issues
• Agent review by hand to further develop
• Manager/Agent meeting establishes issues to be audited
• Ask to speak to Supervisor if expanding scope
• Nuclear Option
• Section 1203(b) – IRS Restructuring and Reform Act of 1998.
• Used for blatant agent misconduct
44
45. CONDUCT OF THE AUDIT (CONT)
Shifting Burden of Proof to IRS
• IRS allows has burden of proof in fraud cases.
45
46. POLLING QUESTION #3
On average, how has your experience with the IRS been
when you have spoken to them over the phone?
1 – Just wonderful
2- OK
3 - Awful
4 - Never spoke to IRS on the phone
46
47. AUDIT CLOSING
• Agreed to agree or disagree on issues
• Discuss disagreed with RA boss
• Always address reduction of penalties
• Haggle over following
• Facts
• Issue trading (possibly include penalties)
• Percentage concessions
• RA less apt to “horse trade”
• Closing Memo, to memorialized is recommended
• Fax to agent so that it becomes part of the “record”
47
48. AUDIT CLOSING(CONT)
• If still disagree, request 30-day letter
• Prepare a protest letter
• Send to RA, requesting an appeal
• Set date/time with Appeals
• Discuss with Appeals Officer
• If still disagree, request 90-day letter
• May get in place of 30-day letter
• If less than 6 mos on assessment statute
• Petition tax court, then referred to appeals
• Otherwise, petition tax court
• Work with IRS Chief Counsel’s office
48
50. APPEALS
• Most cases can be appealed
• AO: Audit/Exam Determination
• SO: Collection Determination
• Audit/Exam
• Exam and then 30 day letter
• Collection
• Administrative
• CAP (Final decision, no judicial review)
• Statutorily
• CDP (Request within 30 Days)/Appeal to Tax Court/Toll
• Judicial review available
• Equivalency Hearing (Request in 1 year)/No TC/No Tolling
• No judicial review
50
D
51. AFTER APPEALS?
Tax Court
• No requirement to pay the tax before hearing
• No jury
• Tends to be less formal
• Especially small cases involving $50K or less
• Many TP represent themselves.
• Normally, judges very helpful to pro se petitioners(TP)
• File petition and pay a $60 Fee
Audit Reconsideration
• In the case of new material facts
51
D
52. AFTER APPEALS?(CONT)
Audit Reconsideration
• Information to be submitted for request
• Statement summarizing issues being contended
• Documents supporting TP position
• Copy of materials furnished to the IRS
• Copies of notices/letter received from the IRS on the matter(s)
• IRS will review
• If disagree can request a conference with Appeals
52
D
53. TAXPAYER ADVOCATE
• Can be used as any point in the process.
• There to assist you in cutting through red tape.
• Cannot just wave a magic wand
• In order to utilize, must have exhaust all admin remedies
https://www.irs.gov/Advocate/Local-Taxpayer-Advocate
Nationwide Phone Number: 1-877-777-4778
53
D