TaxSlaw

Missing the Tax Court’s 90-Day Deficiency Deadline – Now What?
April 23, 2024 | Louis Vlahos | Federal | Income Tax

Notice of Deficiency Over the years, I have observed there is only one thing that a taxpayer fears more than being notified by the IRS that their income tax return for a particular taxable year has been selected for audit, and that is being notified that the IRS has determined…
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IRS Cannot Offset Taxpayer’s Refund With A Disputed Tax Liability
April 18, 2024 | Louis Vlahos | Federal

Use Your Imagination Imagine the IRS notifies Taxpayer that they have an outstanding tax liability with respect to Tax Year, and that the agency intends to levy on Taxpayer’s property to collect the allegedly unpaid tax. Taxpayer challenges the levy, arguing they had already paid the tax. The IRS Office…
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An Inveterate Golfer At the IRS
April 10, 2024 | Louis Vlahos | Federal | Income Tax

Tax Season As we approach the deadline for paying federal individual income taxes and, generally, for filing the returns on which such taxes are determined, some of you may be recalling how the Inflation Reduction Act of 2022 appropriated billions of dollars[i] to the IRS to bolster enforcement of the…
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Trust Fund Recovery Penalty & The Closely Held Business
April 03, 2024 | Louis Vlahos | Business

It’s Still Pretty Bad Depending upon what you read or, perhaps more accurately, depending upon how much you believe of what you read, you may be aware that many closely held businesses are concerned about their future. Most of these survived the disruption caused by the pandemic lockdown only to…
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“C’mon Man! Tax the Rich!” Business Owners Face Tax Increases*
March 25, 2024 | Louis Vlahos | Business

Last week, Sen. Warren reintroduced her “Ultra-Millionaires” wealth tax proposal to the Senate.[i] Query her timing. The measure has the proverbial snowball’s chance in Hell of being enacted by this Congress.[ii] Perhaps the Senator was inspired by the Administration’s Fiscal Year 2025 Budget, which includes its own equally ill-fated –…
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Estate, Gift, GST & Related Income Tax Proposals – What is the White House Doing?
March 15, 2024 | Louis Vlahos | Federal Budget

The Budget is Here![i] Earlier this week the White House released its Fiscal Year 2025 Budget.[ii] Of course, the federal government has not yet adopted a budget for the Fiscal Year 2024 even as we approach that year’s halfway mark. But I digress. The release of the budget comes four…
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Rescission, Repossession, Real Estate – The Three R’s of Unwinding a Sale
March 06, 2024 | Louis Vlahos | Real Estate

Can It Be Undone? How many times have you wished that you could undo something from your past, perhaps a string of incoherent statements made at a client dinner while slightly under the influence, or an expletive-filled email composed and sent in anger?[i] Often enough, right? I’m certain that those…
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Transfers Within the Family Business: Gifts or “Ordinary Course” Transactions?
February 22, 2024 | Louis Vlahos | Business

Crossing the Streams[i] It is not uncommon, in the context of a business entity in which a family owns a controlling or substantial interest, for an adviser to encounter intersecting gift and income tax issues. This week’s post will consider one such instance in which the IRS was asked to…
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Shareholder-Transferee Liability for a Corporation’s Income Tax
February 14, 2024 | Louis Vlahos | Business | Income Tax

What Corporate Shield? Would you be surprised to learn that most shareholders of closely held corporations, and especially those with minority or merely passive interests, believe they cannot be held responsible for the tax obligations of their corporations? I, for one, would not. Over the years, I have both experienced…
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The Family-Owned Business, Stock Options, And Personal Goodwill – a Smorgasbord of Tax Issues
February 08, 2024 | Louis Vlahos | Business

Passing the Torch Many of us have encountered variations of the following scenario: a parent owns and operates a business; one or more of their children are employed in the business; as the children mature and become more experienced and established in the business, some of them may want to…
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