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On February 23, 2021, the U.S. Tax Court rule in favor of our client that acquisition of credit card reward points, no matter how many the receive, is not a taxable event.  In Anikeev v. Commissioner, the IRS tried to tax credit card reward points that the taxpayer received claiming they were “ca...
Given that the focus of my practice is civil and criminal taxpayer representation, I am excited to be teaching again at the National Association of Tax Professionals TaxCon 2021! Join us for this terrific virtual annual conference where I will be covering "Dealing with the IRS Collection Division...
On January 11, 2021 the U.S. District Court in Connecticut decided USA v. Kaufman and held that the maximum penalty for unintentionally failing to file FBARs is $10,000 per year. Not $10,000 per account. This is a major victory for taxpayers as the IRS has sought to use the non-willful FBAR pena...
Join us this Thursday June 4th for a free two hour program on IRS Offers-in-Compromise vs. Bankruptcy, and when you and your clients should choose one resolution alternative over the other.  Joining me will be Amanda Evans, EA and Joanna Kornafel, Esq. and we will walk through the IRS OIffer-in-C...
The Paycheck Protection Program (“PPP”) is geared to small business. The Small Business Administration (“SBA”) uses a very specific and complicated definition to determine which businesses can generally qualify for SBA loans. Generally, qualifying business must be a “small business concern” to ob...
Over the past week, I’ve been asked whether there is anything in the CARES Act that can facilitate entrance, DIP, or exit financing for a chapter 11 debtor? The short answer is likely not the longer answer is maybe.The Act delegates rule making authority to Treasury and the SBA. Given the short t...
 For the past several weeks I have been closely following the legislation and rule making concerning the CARES Act, payroll protection loans, and related provisions.  One of the most confusing is how attribution/affiliation rules apply to companies that want to take out payroll protection loans. ...
The Internal Revenue Service today urged taxpayers to be on the lookout for a surge of calls and email phishing attempts about the Coronavirus, or COVID-19. These contacts can lead to tax-related fraud and identity theft."We urge people to take extra care during this period. The IRS isn't going t...
As expected, Purdue Pharma has commenced proceedings in the Bankruptcy Court to obtain injunctive relief, seeking to put a stop to the numerous pending lawsuits brought against Purdue and its affiliates in connection with the opioid crisis.  Purdue’s adversary complaint, filed Wednesday evening, ...
We represent business owners and individuals in bankruptcy and commercial litigation frequently.  On March 31, 2019, in Wood v. Dept. of Housing & Urban Development (In re Wood), 18-5006 (Bankr. S.D. W.Va. Mar. 31, 2019), the court addressed the issue concerning whether a debtor’s tax overpayment...

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