Internet Tax Lawyers

Author: Igor S. Drabkin, J.D., Former IRS Attorney.

Former IRS Attorneys of Holtz, Slavett & Drabkin are available to answer your questions about the foreign bank accounts requirements, applicable penalties, and guide you through this voluntary disclosure program.  We can be reached at (310) 550-6200.

Copyright (c) 2009 Igor S. Drabkin.  All Rights Reserved.

The IRS also announced that there will be no further extensions.

Under the IRS amnesty program issued in March, taxpayers with hidden foreign financial accounts originally had until Sept. 23, 2009 to come forward.  As the incentive for coming forward, the taxpayers avoid criminal prosecution and face reduced penalties.

So far, more than 3,000 American taxpayers applied for the voluntary disclosure program.  Pursuant to requests from tax attorneys and practitioners, the IRS decided to extend the September 23rd deadline. By extending the deadline for a short period of time, until October 15, 2009, the IRS is providing relief for those taxpayers who had intended to come forward prior to the deadline, but faced logistical and administrative difficulties in meeting it.  The extension will allow taxpayers and their attorneys and representatives additional time to evaluate taxpayers’ situation and prepare the necessary paperwork to qualify for the special penalty provisions.

The Internal Revenue Service announced on September 20, 2009, a one-time extension of the deadline for special voluntary disclosures by taxpayers with unreported income from hidden offshore accounts. These taxpayers now have until Oct. 15, 2009 to make a voluntary disclosure.

Steigerwalt Law Firm is a DUI attorney in San Diego

If you have been arrested for drunk driving, you should:

For more information regarding San Diego DUI law, please visit our website http://www.sdcountydui.com

Advice from San Diego DUI lawyers who have handled thousands of cases

• Think carefully before you refuse to take a preliminary alcohol screening (PAS) test. Refusing to take a roadside PAS is often seen by a police officer as implying guilt and reflects negatively on you, even if you have not been drinking. A DUI test refusal frequently leads to arrest and may result in the loss of your license and jail time.
• Tell the arresting police officer you want a lawyer. Doing so makes it clear you know you have legal rights and wish to exercise them. Additionally, the police cannot continue to question you without your lawyer present once you have requested one.
• Exercise extreme caution before you speak. Even casual statements you make can be used against you during your criminal trial or administrative hearing. The prosecution can and will bring up any admissible statements you made if it bolsters their case against you.
• Not believe everything the police officers tell you. Sometimes officers give those under arrest misleading information in an attempt to obtain a confession of guilt. They may exaggerate the penalties you face or use other tactics to coerce you into making compromising statements.
• Find a lawyer to take your case. Hiring an attorney is an important step to take if you have been arrested for drunk driving. Choose an attorney who has specific experience handling DUIs in San Diego, and who you feel comfortable working with. It is important you have confidence in the services your lawyer provides.
• Solicit to gain a portion of the sample you gave to have it tested by an outside professional. DUI tests do not always produce accurate results. Having a third party test your blood or urine sample may produce a different outcome than the original test.
• Prepare to go to court for your arraignment. If you intend to plead not guilty, additional court dates will be set.

You must treat being arrested for driving under the influence (DUI) of alcohol or drugs extremely seriously.  Depending on the circumstances of your DUI, you may be convicted of committing a misdemeanor or felony crime. The results of a conviction include penalties ranging from the revocation of your driving privileges to jail time, and can come back to haunt you in the years to come.

Amazon’s reference to agreeing to “an immaterial payment to the state” suggests that it had to pay something toward settling the prior years’ assessment. That point may be of interest to other businesses, and their tax advisers, that are currently considering settlements of their Texas tax disputes. Perhaps the Comptroller’s office will clarify things by posting the agreement itself on the agency’s web site, with appropriate redactions to protect Amazon’s confidential information.

This morning, the Texas Comptroller of Public Accounts posted a press release on the agency’s web site, the Window on State Government, announcing that the Comptroller’s office and Amazon.com, Inc., have entered into an agreement under which Amazon plans to create at least 2,500 jobs and make at least $200 million in capital investments in Texas over the next four years. What’s more, Amazon will begin to collect and remit Texas sales tax on July 1, 2012. But here’s the key part of the press release:

That statement refers to the sales tax assessment of approximately $269 million that the Comptroller made against Amazon back in 2010. Amazon’s latest Form 10-Q, coincidentally filed with the U.S. Securities and Exchange Commission today, provides some further details about that assessment and the resolution with the Comptroller’s office:

The agreement resolves all sales tax issues between Texas and Amazon.

In September 2010, the State of Texas issued an assessment of $269 million for uncollected sales taxes for the period from December 2005 to December 2009, including interest and penalties through the date of the assessment. The State of Texas alleged that we should have collected sales taxes on applicable sales transactions during those years. While we continue to believe the assessment was without merit, in April 2012, we entered into a settlement with the State of Texas that included an agreement to collect sales taxes on applicable sales transactions for our US-focused internet retailers beginning July 1, 2012, resolution of Texas sales taxes up to that date, certain commitments related to capital investment and job creation in the state, and an immaterial payment to the state.

Related posts:

1. If You Owe the IRS Back Taxes, There Are Tax Relief Options Available
2. Owe IRS Back Taxes? The Offer in Compromise or Installment Agreement are Options for Tax Relief
3. Solicit the Tax Resolution Expert: The IRS Offer in Compromise or Installment Agreement Programs May Be Your Tax Debt Solution

If you are in a position where you are unable to pay down your tax debt, even over time, then the Offer in Compromise may be right for you. The IRS developed this program after discovering that the tax-collecting agency can actually bring in more revenue from indebted consumers by being kind and gentle. That is to say, instead of chasing you for money and receiving little, the IRS is willing to negotiate on a settlement offer that will close out your tax debt once and for all. This settlement offer can amount to a significant discount. If you are eligible for this program, you and your tax attorney should meet with the IRS.

Question: I owe a lot in back taxes to the Internal Revenue Service. I’m not sure how I’ll ever get paid up. Plus, it’s been several years, and I think it’s too late for any of the programs you’ve discussed. What can I do?

Alternatively, the Installment Agreement might be a good option. This IRS Payment Plan program allows you to pay down your debt over time, just as you would pay for a car or house using traditional financing.

Answer: First of all, it’s not too late. Actually, it’s never too late. If you owe money to the Internal Revenue Service, you have many options available to you, no matter how long it’s been since your first overdue tax dollar.

In all honesty, your situation likely isn’t as bad as you think. The first thing you should do is to consult a qualified tax attorney. In a situation such as yours, it’s not uncommon to find that earlier errors in your tax returns resulted in an inflated amount of tax debt to the IRS. A qualified tax attorney will analyze your returns with a fine-toothed comb to make sure that the amount you are reporting you owe is accurate. This promise can often to lead a substantial reduction in your tax debt.

Once that is finished, you’ll need to decide next which program is best for you to eliminate your tax debt once and for all.

News agencies were abuzz about Wednesday’s Supreme Court decision stating the IRS could not use the extended, six-year statute of limitations to collect unpaid taxes from a business, Home Concrete & Supply, LLC in a tax shelter case. Robert Wood of Forbes in his article HUGE Taxpayer Win: Supreme Court Tells IRS 3 Years to Audit Is PLENTY! believes the historic decision regarding this tax shelter case will have a “trickle-down effect” and impact dozens of related cases who might be breathing a collective sigh of tax relief from this ruling.

The tax code allows the IRS to audit 3 years back, but an IRS audit can be extended to 6 years in cases where a taxpayers don’t report 25% or more of their income. Home Concrete & Supply LLC, happened to be a business the IRS has been watching as part of an investigation and crackdown on the “Son of Boss” tax shelters; a case that involved omitting 25% of gross income.

Home Concrete & Supply was a limited liability company formed in 1999 by North Carolina businessmen, Robert Pierce and Stephen Chandler, who owned a small oil and coal company. The company was formed specifically to facilitate a “Son of Boss” scheme. Here is a timeline of their IRS tax issues:

But don’t be fooled, the IRS may be down but certainly not out!  Recent collection statistics show enforcement efforts especially for unreported offshore accounts paying off; $2.7 billion alone was gained in tax revenues from 2009 & 2011 from the Offshore Voluntary Disclosure Initiatives.

The History of Home Concrete & Supply, LLC

• These tax shelters first appeared in the late 1990s.
• They have become some of the costliest tax schemes in U.S. history.
• “Boss” is an acronym for “bond and option sales strategies”
• They create paper losses that offset real gains.
• The IRS began its crackdowns on “Son of Boss” shelters in 2000.
• By 2005, 1,165 people had settled such cases with the IRS.
• These schemes use inherently complex structures that are difficult for IRS investigators to uncover within a three year period.

Related posts:

1. Swiss Bank Wegelin Avoids Court Appearance
2. Offshore Tax Evaders Get Preferred IRS Help
3. Swiss Pressured to Reveal All Offshore Accounts

What are “Son of Boss” Tax Shelters?

• Filed 1999 taxes in 2000.
• Audited for 1999 by the IRS in 2006.
• Billed in 2006 for $6 million in unpaid taxes.
• That same year, the partners sued the IRS claiming the agency only had three-year statute of limitations to claim their unpaid taxes.

For more tax tips and information, visit our Tax Resolution University blog regularly. Also, check out our helpful tax advice videos on our YouTube channel!

A Reuters article Supreme Court restrains IRS in tax shelter case, explained the significance of “Son of Boss” shelters to the IRS:

Subsequently, this case went all the way to the Supreme Court where it ruled in the company’s stating that 3 years not 6, was sufficient time for the IRS to collect their back taxes. The high court’s ruling dashed $1 billion in tax revenues from about 30 related cases involving “Son of Boss” tax shelters the IRS was anticipating.

Remember: All unpaid back taxes whether they are illegal tax shelters or tax liens involve steep fines and IRS penalties that increase daily. Don’t wait for the IRS to approach you – hire an expert tax attorney or certified tax resolution specialist who can bring you into IRS compliance and help you avoid any tax problems in the future.

A Gatlinburg, Tenn., couple was sentenced for subscribing to false tax returns that resulted in a $550,649.13 tax loss. Kevin Matthew Flannery, 65, obtained 24 months in prison. Margaret Anne Flannery, 63, received three years of probation and one year of home confinement.

No related posts.

Kevin Flannery pleaded guilty to one count of subscribing a false tax return for M.K.M.K. Associates Inc., doing business as Southland Car and Jeep Rental, for tax year 2003. Margaret Flannery pleaded guilty to one count of subscribing a false tax return for X.M.K.M. Enterprises Inc., doing business as Famous Fries, for tax year 2002. The Flannerys skimmed cash from both companies, not providing accountants with the true gross receipts and underreporting taxable income.

Sedacca v Kelly, 2012 NY Slip Op 01319, Court of Appeals The Court of Appeals has ruled that the Nassau County Executive did not have the authority to terminate Commissioners of the Nassau County Assessment Review Commission (ARC), in the…

Over the past 5 months, the IRS has issued 52 answers to frequently asked questions regarding the IRS’ Offshore Voluntary Disclosure Program.  The questions and answers provide valuable guidance into the offshore voluntary disclosure program and should be reviewed prior to making a voluntary disclosure. 

Former IRS Attorneys at Holtz, Slavett & Drabkin are available to answer your questions about foreign bank account reporting  requirements, applicable penalties, and guide you through the voluntary disclosure program.  We can be reached at (310) 550-6200.

Taxpayers have until October 15th to make a voluntary disclosure of foreign accounts under the IRS amnesty program.

Author:  Gary M. Slavett,  J.D., LL.M., Former IRS Attorney

A. Class I recalls are the most serious of all types of recalls and are issued when a product could cause potentially fatal side effects. Class II recalls are issued when a product could cause minor injuries and the overall risk of injury is low.

Q. What is the difference between a Class I recall and a Class II recall?

A. Medtronic’s SynchroMed II and SynchroMed EL Infusion pumps are medical devices used to manage pain in patients recovering from serious surgeries. Infusion pumps are implanted surgically and pain medication is released to the location of the affected area by battery power. Infusion pumps are commonly used to treat patients suffering or recovering from spinal surgery, shoulder arthroscopy, cancer, and spasticity.

A. Examples of damages victims may gain compensation for in a Medtronic Infusion pump lawsuit, include medical expenses, rehabilitation, care giving services, lost income due to the inability to work, disability, loss of quality of life, and pain and suffering. To learn what types of damages you may be able to collect in a Medtronic defective Infusion pump lawsuit, phone a skilled personal injury lawyer. Most Medtronic Infusion pump refill kit lawyers offer free consultations.

Q. What types of compensation can be recovered in a Medtronic Infusion pump lawsuit? 

Q. Why were the Medtronic Infusion pumps recalled?

Q. What is a Medtronic Infusion pump used for?

A. The SynchroMed II, SynchroMed EL, and some pump refill kits were a part of a Class I recall issued September 2011 by the Food and Drug Administration. The pumps were recalled because of two problems – one involving the battery and one involving the pump’s refill procedure. Researchers discovered that a film could develop over the battery, which could affect the battery’s performance and ultimately, the pump’s ability to release the right amount of medication. Researchers also discovered that during the refill procedure medication could be released under the patient’s skin, instead of into the pump.

A. If you suffered as a result of a recalled Medtronic Infusion pump, you may be eligible to seek compensation from the manufacturer. However, if you are considering taking legal action, it is highly recommended you seek quality legal representation. It is imperative you hire a lawyer with the financial resources and legal expertise needed to go up against a large company like Medtronic. With a qualified Medtronic Infusion pump recall attorney by your side, your chances of a successful case outcome are significantly higher than if you were to handle the case on your own.

Q. I suffered after receiving a Medtronic Infusion pump. Can I take legal action against Medtronic?

The Constitution has some pretty clear language set up to restrict states’ abilities to regulate interstate commerce. So before any legislation is determined, this question will have to be answered, most likely by the U.S. Supreme Court.

Click on the link to access other helpful IRS Tax Help Articles

IRS tax issues surrounding e-commerce are complicated and bring up questions whether affiliate nexus tax is constitutional. But with states clawing for every tax dollar, they’re likely preparing for a long fight. California projects that it loses several hundred million dollars in tax revenue a year and has passed a law to enact more stringent policies on the companies selling to Californians.

Related posts:

1. Ask the Certified Tax Specialist – Small Business Back Taxes
2. Rapper Nas and His Giant IRS Tax Issues
3. Three IRS Options to Pay Tax Debt

Would an e-Commerce Sales Tax Chase Out-of-State Customers Away?

Fortunately, the matching program was suspended indefinitely, due to some backlogging concerns. But it’s only a matter of time before the IRS fires up the matching check program again and companies find themselves with tax debt issues. Companies are advised to get their books in order.

The explosion of e-commerce businesses has been due in part to the low-cost of entry. Many claim it’s resulted in a small-business renaissance with larger corporations in search of market share and start-up investment firms such as Kickstarter ready to provide capital to those who never thought it was possible to make their hobby into a full-fledged profit-making business venture. But lagging behind has been government regulation of not only the proprietors selling their goods but also the marketplace sites themselves. Virtual business owners are now forced to adapt to constantly changing taxation demands and government attempts to capture tax revenue from e-commerce transactions.

Advances in technology including access to wireless internet connections have created new business opportunities such as virtual worldwide retail spaces for thousands of proprietors who now can sell their talents on the Internet with sites such as eBay, Amazon, and Etsy. These consumer-to-consumer internet shopping websites sell a variety of goods ranging from camping gear and jewelry to electronics and original fine art.

Many believe sales tax could be the end of small e-commerce businesses with some municipalities finding out the hard way. The city of Springfield, Illinois, passed the affiliate nexus tax requiring out of state e-commerce businesses selling merchandise to Illinois residents and who advertising locally to charge a 6.25 percent tax and pay it to the state government. Some large e-commerce businesses, including Amazon.com pushed back on such legislation stating it wouldn’t ship to states with steep sales tax. Their gross margin reduces to the point that it’s not worth selling to them.

Here are questions on this subject that will need to be answered sooner rather than later:

How will a Virtual Businesses without a Nexus be Taxed?

The Internet has enriched our lives and made some things easier, but it didn’t make life simpler especially for those with virtual businesses. I recently wrote an article regarding e-commerce tax issues entitled “The E-Commerce Conundrum: Taxing Virtual Businesses and Their Investors and the Law” explaining that e-commerce businesses not only face IRS tax problems but also pressure from state legislatures to collect and pay state taxes.

Is the Taxing of e-Commerce Businesses and Their Investors Constitutional?

New state tax laws bring new tax problems in figuring out how to enforce the laws. There are several key obstacles that the government has faced with regard to keeping tabs on the e-commerce sector. The IRS has created a special task force to monitor and enforce the following:

• Online payment accounts such as PayPal to access suspicious accounts and audit PayPal records.
• Monitor businesses showing a high volume of customer ratings to determine:
  • If the company is doing high volume sales
  • If the company is applying appropriate sales taxes when shipping
  • Legally check companies’ shipping and sales tax policies posted on their e-tail site to determine whether or not they should be audited. No tax info could reveal non-payment of back taxes.
  • Deploy its matching check program giving the IRS access to a company’s credit card transactions to match if they are accounted for on their books.
  • Implementation of form 1099s to all customers paying for products and services with a credit card; a paperwork nightmare for the small business person.

The U.S. as a nation is clearly making significant decisions about how or if it wants to define the e-commerce marketplace. As a tax specialist who helps individuals and businesses reconcile past IRS debts, I have yet to see any clients with auditing or legal issues regarding e-commerce laws, mainly because the subject is new. However, one thing is for sure, legal decisions going forward will significantly impact the future of e-commerce. I fully expect to see an increase in e-commerce business owners facing IRS audits and needing IRS tax relief due to unpaid sales taxes, as well as an increase in lawsuits as small businesses try to keep up with the ever-changing, exceedingly complex United States tax code.

Big businesses have lobbied for tax help in the form of a tax on companies with an “indirect presence” in the state claiming they were at risk of being undercut by e-commerce companies not charging sales tax in the long run.

Is Big Businesses Impacted by e-Commerce Presence?

Many virtual businesses don’t have a physical place of business in a specific state to be taxed accordingly. Some lawmakers and tech industry folks believe virtual start-up’s should be given special tax incentives because, the reason those who earn a living without using their car, don’t pollute the atmosphere as much and leave a smaller footprint on the environment.

Here are seven basic recommendations for keeping tax documents both individuals and small businesses can follow:

If you missed the April 17 deadline to file your tax returns, you have some options, but act quickly to stop the mounting IRS penalties and interest associated with non-filing.  Get tax relief now from a tax attorney or certified tax resolution specialist who can guide you through the morass of daunting IRS regulations, rules, protocol and paperwork to find the best solution to your IRS tax problems.

Like clockwork, about a week or two after the April 17 tax deadline, I begin fielding taxpayer questions regarding what tax documents to keep and for how long.  A recent article in Forbes by Tax Girl Kelly Phillips Erb entitled How Long Should You Keep Records after Tax Day? provided good guidelines on the subject.

• W-2 and 1099 forms
• Bills, credit card and other receipts
• Invoices, mileage logs, canceled, imaged or substitute checks, proofs of payment
• Other records to support deductions or credits you claim on your return

1. Taxpayers foolish enough to under report more than 25% of their gross income will need to keep those records for six years because the statute of limitations is extended. Important note: Under reporting income creates unnecessary tax issues especially since the IRS has hired more agents to go after missing back taxes with a vengeance. It’s best to play it safe and report ALL income.
2. Anyone foolish enough to file a fraudulent return or not file at all must hold onto those tax records indefinitely because the statute of limitations never expires and eventually the IRS will request for them. As recommended, it’s just easier to file properly.
3. For property deductions such as depreciation, amortization, or depletion, those records should be kept for as long as the property is owned. Documents to hang on to include: deeds, titles and cost basis records and if special credits and deductions are claimed, keep those records for no less than 7 years.
4. Have employees? Keep all employee records including in-home employees for at least 4 years after the date the payroll taxes become due or paid. These records will be handy should you ever face an IRS audit. Forms to save include: W-2 and W-4, and all related pay information including benefit forms.
5. Keep tax records organized! Last minute scrambling to organize documents is a waste of time. Organized record keeping will require some work but well worth the effort should need to present your books to the IRS. Saving your receipts will ensure you have back up for justified deduction claims. Rule of thumb: when in doubt, save.
6. Use technology to your advantage; store tax documents electronically! The IRS has accepted scanned receipts since 1997 but you must ensure the following:

• That scanned or electronic receipts are as accurate as the paper records
• That scanned records can be properly indexed, stored, preserved, retrieved, and reproduced should you need to produce a hard copy form. A previous blog post discusses the benefits of storing important documents electronically.

Important point: Make sure that you check with your tax professional before getting rid of important records. If you get a green light from your CPA and your files are really, really old– don’t just shred, create art out of them.

Related posts:

1. Finding Tax Help for IRS Tax Debt
2. Michael Rozbruch Interviewed in Opportunist Magazine
3. Request the Certified Tax Specialist – Small Business Back Taxes

In general, most taxpayers should keep tax records and supporting documents for three years following the date of filing or due date of the tax return. Example: filed your return on April 17, 2011? Save all documents April 17, 2015. Supporting documentation includes:

No related posts.

Knowing that the false information contained in these forms would be used to create tax returns claiming refunds for himself and the family member, Pirrone caused the fraudulent forms to be submitted as purportedly legitimate to commercial tax return preparers. The forms were used to prepare false income tax returns for 2003 through 2008, which were filed with the IRS on behalf of Pirrone and the family member.

Stephen Pirrone, 51, of Norwood, N.J., previously pleaded guilty to two counts of an indictment charging him with filing false, fictitious and fraudulent tax returns. According to court records, Pirrone created false W-2 forms for himself and a family member that contained fabricated names of employers and names of employers who did not employ Pirrone or the family member, and which contained fabricated amounts of tax withholdings.

Pirrone allegedly acquired more than $200,000 in tax refunds from the IRS as a result of his scheme.

A Bergen County, N.J., man was sentenced to 28 months in prison for his involvement in a scheme to file fraudulent tax returns that claimed more than $200,000 in tax refunds.

After criticism from the National Taxpayer Advocate, the IRS has taken steps in recent years to reform and improve the offer in compromise program. These steps included making the OIC process smoother for ordinary taxpayers whose debts or income were below certain thresholds. People have responded to the improvements by filing more offers, with the IRS reporting an increase of more than 13,000 offers between 2007 and 2011. The effect of the recent recession has also caused more taxpayers to seek the aid of an OIC.

But the OIC program still remains a valuable and effective tool for taxpayers with difficult tax debts. The IRS has stated that it will take steps to respond to the offers more efficiently, including adopting a smoother process for all offers.

But the TIGTA report indicates that the IRS was not prepared for the increase in offers in compromise. The agency uses two locations to respond to offers, and TIGTA revealed that the number of offers exceeded their capacity to handle them. Over 7,000 offers were not even assigned to an IRS employee yet, and some had not been dealt with in over half a year. The IRS can transfer offers from one location to another, but both were so overloaded that one could not have helped the other process offers any faster.

Source: Forbes, “Trying To Come Clean With The IRS? Get In Line.” Ashlea Ebeling, April 12, 2012.

For some California taxpayers with burdensome tax debts, an offer in compromise, commonly abbreviated OIC, can provide relief. Under an OIC, the Internal Revenue Service agrees to accept less than the full amount of a person’s tax liability in satisfaction of the debt. Many taxpayers are discovering that the relief provided by an OIC is slow in coming, however, according to a Treasury Inspector General for Tax Administration report.

The High Bench v. the Ivory Tower is an interesting Feb. 1, 2012 ABA Journal article. Anyone interested in legal scholarship should read it. It discusses whether legal scholarship means anything today. It points to recent statements by Chief Judge…

The Acting General Counsel just issued a 24 page Guidance Memo on Representation Case Changes, GC-12-04 (April 26, 2012), Download Guidance memo GC 12-04 4.27.12 Mitchell H. Rubinstein

Copyright (c) 2009 Igor S. Drabkin.  All Rights Reserved.

Author: Igor S. Drabkin, J.D., Former IRS Attorney.

We remind everyone that the deadline for voluntary disclosing foreign financial accounts to the IRS expires on October 15, 2009.  On September 21, the IRS extended the deadline to October 15th, but specifically stated that this deadline will not be extended.

Igor S. Drabkin, J.D., Former IRS Attorney

If you have questions about the Offshore Voluntary Disclosure program or FBARs, please contact Former IRS Attorneys of Holtz, Slavett & Drabkin at (310) 550-6200.

Another client of UBS AG, one of the Swiss banking giants, has pleaded guilty to filing a federal income tax return.  According to the U.S. Department of Justice, Roberto Cittadini of Bellevue, WA, accepted responsibility for concealing nearly $2 million in Swiss bank accounts. Cittadini failed to report income from bank accounts under his control at UBS in Switzerland on his individual income tax returns from 2001 through 2003.  He also failed to file a Report of Foreign Bank and Financial Accounts (FBAR) for each of those years. He faces a maximum sentence of three years incarceration and a maximum fine of $250,000, DOJ said, adding that Cittadini agreed to pay a civil FBAR penalty based on 50% of the highest account balance from 2001 to 2007. Cittadini’s guilty plea follows recent guilty pleas in UBS-related cases by individuals in California, Florida, New Jersey and New York.  “Individuals all over the country who are hiding income and assets in offshore accounts would be well-advised to promptly come in and come clean before the government learns about their accounts through other channels,” said John DiCicco, acting assistant attorney general of the Justice Department’s Tax Division. “IRS continues its pursuit of those hiding their income and assets in offshore accounts,” said Eileen Mayer, Chief of IRS’s Criminal Investigation. “We encourage people who have been hiding money offshore to come forward by Oct. 15 to take advantage of the special provisions in our voluntary disclosure effort.”

     It may be trendy to wear clothing capable of concealing a gun in New York
City, but concealing and carrying a weapon is still illegal in
Illinois.  The New York times recently published an article that stated
that clothing manufacturers are producing clothing that hides handguns.
http://www.nytimes.com/2012/04/24/us/fashion-statement-is-clear-the-gun-isnt.html?smid=tw-nytimes&seid=auto
    That article correctly notes that in Illinois it is illegal to conceal and carry weapons on one’s person.

Chicago, IL 60601

Attorney at Law

180 N. LaSalle, Suite 3700

levin@lorilevinlaw.com

   In Illinois, a civilian may not carry a concealed weapon on his person.

Although
the Illinois Supreme Court in People v. Leonard Holmes, Jr., 241 Ill.2d
509, 948 N.E.2d 617, 350 Ill.Dec. 337 (2011), indicated that the
statute’s enhanced penalties for failure to have a valid Illinois
Firearms Owner Identification Card do not apply for nonresidents who are
currently licensed or registered to possess a firearm in their home
state, that registration does not negate guilt for the underlying
offense of unlawful use of a weapon.

Lori G. Levin

www.lorilevinlaw.com

Lori G. Levin is an experienced Illinois litigator whose practices focuses mainly on criminal, juvenile and mental health issues.

312-972-3756

Get help from a tax attorney. Call Mitchell A. Port at (310) 559-5259.

Forbes Online also has a good explanation of what’s going on at the IRS with regard to the OICs which is available at this link.

Why are Offers up? In part the struggling U.S. economy is responsible, and in part it’s the IRS’ own doing. Since the National Taxpayer Advocate labeled the offers in compromise program as one of the most serious problems facing taxpayers from 2001 through 2009, the IRS has been trying to improve and promote the program. It made the OIC form (Form 656) simpler, created a YouTube informational video and began a “streamlined” process for taxpayers with incomes of $100,000 or less and liabilities of $50,000 or less to make deals. A “Fresh Start” initiative is also bringing in more taxpayers to the OIC program.

At the end of last month, the U.S. Treasury published a report entitled “Increasing Requests for Offers in Compromise Have Created Inventory Backlogs and Delayed Responses to Taxpayers” which is available by clicking here.

The IRS faces a 28% increase in the number of requests for Offers In Compromise. The requests by Californians and others behind in their tax payments to pay “pennies on the dollar” has reached almost 60,000 for 2011 when the data was last analyzed.

Get Your Own Damm Coffee is an interesting Feb. 13, 2012 article from Slate where it highlights the abuse some interns may face because they are not employees. The article discusses the FMLA, but if interns are not employees they…