Millions of U.S citizens have hobbies such as photography, travel, sewing, crafting, hunting, floral design, and coin collecting. By the IRS definition, a hobby is an activity that is not pursued for profit. On the other hand, a business is an activity that is carried out with the intention and expectation of earning a profit. […]

A stretch IRA is an estate planning strategy that extends the life of an Individual Retirement Account (IRA) by allowing the original beneficiary to distribute the assets to a designated second generation beneficiary. This strategy allows the IRA to be passed on from generation to generation while extending its tax-deferred growth for years or decades […]

Eli S. Noff, Esq.CPA, Partner The IRS is now actively in the process of issuing Notices CP508C to hundreds of thousands of U.S. taxpayers–placing all notified taxpayers’ passports in serious jeopardy. Several news outlets this week report that the U.S. State Department confirms that it has already acted on its part in the process and […]

Eli S. Noff, Esq.,CPA, PartnerBrent Conrad For tax purposes, a non-U.S. citizen is either a nonresident alien or a resident alien. All aliens are considered nonresident aliens, unless they pass the green card test or the substantial presence test. A person meeting either of these tests is considered a resident alien. Since aliens are taxed […]

Glen E. Frost, Esq., CPA, Managing Partner For many years, the persistent call for change in the taxation of American corporations and individuals abroad has gone unanswered. However, the current administration’s actions, suggest the very real possibility of new tax rules, sooner rather than later. Indeed, assuming no major legislative disturbance or some catastrophe, such […]

Eli S. Noff, Esq. Partner The recent Tax Court’s Alterman v. Commissioner [1] decision is a lesson in Accounting 101 for Cannabisseurs. Well, technically it’s a valuable lesson about record-keeping to all taxpayers who are subject to Internal Revenue Code (I.R.C.) §280E — but with the currently high audit rates for the marijuana industry, it’s […]

On April 5, 2018, the Chief Counsel’s Office provided advice in Notice CC-2018-005 to Chief Counsel attorneys who handle I.R.C. §7345 passport actions. The Chief Counsel’s Office detailed both the certification and reversal processes for “seriously delinquent taxpayers,” as well as the procedures for the judicial review of certifications. Lastly, the Notice indicates that since […]

Rebecca Sheppard, Esq. Have you ever considered filing an offer in compromise with the IRS to “settle your debt for pennies on the dollar”? Until recently, filing an offer in compromise was believed to create an automatic hold on collection action–i.e., the IRS would not be able to levy your property once it was filed. […]

Eli S. Noff, Esq. CPA, Partner Wesley Snipes and the IRS have been at odds for many years. From 1999 to 2001, Snipes simply didn’t file returns and failed to pay millions of dollars in taxes. For his part, Snipes has denied being a tax protestor; rather, he claims to have relied on professional advice […]

Eli Noff, Esq.,CPA, Partner The taxpayer in Berkun v. Commissioner1 ultimately raised two collection due process arguments too late for consideration on appeal, but the Eleventh Circuit apparently found them worthy enough to highlight in a published opinion. Although the Eleventh Circuit uses a popular Seinfeld reference to describe its own non-substantive ruling in Berkun […]