2024-05-27 Misleading Silences Are Sometimes Fine in Tax

05/27/24 • -1 min

This week we look at:

Yet another PLR requested for missed QSST election after S shares moved to trust following death of a shareholder
Tax preparer’s conviction for willfully filing false returns upheld on appeal despite his argument he had doing what he did for years
Letters to taxpayer from IRS Appeals did not extend the time to file suit for a claim for refund
A partnership had properly elected to use BBA audit provisions early, rendering IRS FPAA invalid

An audio only update for htis week’s session can be streamed or downloaded below:

A PDF with the slides and this week’s links can be downloaded below:

This week we look at:

Yet another PLR requested for missed QSST election after S shares moved to trust following death of a shareholder
Tax preparer’s conviction for willfully filing false returns upheld on appeal despite his argument he had doing what he did for years
Letters to taxpayer from IRS Appeals did not extend the time to file suit for a claim for refund
A partnership had properly elected to use BBA audit provisions early, rendering IRS FPAA invalid

An audio only update for htis week’s session can be streamed or downloaded below:

A PDF with the slides and this week’s links can be downloaded below:

This week we look at:

DOJ issues proposed rule that would remove cannabis businesses from loss of most business deductions under IRC §280E
Filing date relief issued for those impacted by Ohio tornadoes from March
IRS National Fraud Counsel speaks on ERC exams in ABA Tax Section webinar
Tax adviser files suit to attempt to force the IRS to start processing ERC claims
Tax Court imposes penalty for raising frivolous claims against taxpayer who argued wages are not income (among other things)

An audio only version of this week’s broadcast can be streamed or downloaded below:

A PDF with a copy of the slides and links to the supporting documents can be downloaded below:

This week we look at:

IRS announces that Direct File will continue into 2025 and be expanded while maintaining other programs
A taxpayer finds its not so simple as just file a Form 2553 if you want to have an LLC taxed as an S corporation, but did realize the error fast enough to get a PLR to restore S status

An audio only version of this week’s broadcast can be downloaded below

A copy of the slides and this week’s link to items mentioned can be downloaded below: