Blog Posts in 2018

100 Examples of the 80/20 Rule

Also known as: The Pareto Principle The Principal of Least Effort The Principal of Imbalance The Law of the Vital Few and the Trivial Many The More with Less Principal The Rule The 80/20 Rule asserts ...
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Taxation of Lawsuit Recoveries: 10 Points of Law

The same tax rules apply whether the award is made by settlement (before or after lawsuit) or awarded through a judgment. But the parties can influence taxation by inserting pivotal facts in a ...
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Tax Court Filing Deadlines are Not Extendable

Tax law is harsh when it comes to most filing deadlines, which are considered jurisdictional and not subject to equitable tolling. Even one day late, regardless of the harshness of result, will block ...
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Is your Tax Accountant Covered under the Attorney-Client Privilege?

Under the tax code, the confidentiality privilege only applies in non-criminal tax matters. But United States v. Kovel (2nd Cir. 1961) stepped in to extend the attorney-client privilege to cover ...
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The Government can Compel Disgorgement of Tax Return Preparer's ill-gotten Gains, says Federal Appeals Court.

The case referred to is U.S. v. Stinson, a federal appeals decision that affirmed the disgorgement (repayment) of $949,952.47 against a tax return preparer. Disgorgement, which compels wrongdoers to ...
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The National Taxpayer Advocate Points to Systemic Flaws within the IRS

Despite the IRS' recent achievements, and its 5-year Strategic Plan to streamline operations, The National Taxpayer Advocate exposed some core weaknesses. The National Taxpayer Advocate (NTA) is ...
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Despite Budget Restraints, The IRS is Committed to Improving Quality

The IRS published its 5-Year Strategic Plan for years 2018 to 2022. Below are some of its strategic goals. Honoring the Taxpayer Bill of Rights; Encouraging more online interaction to increase ...
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The Importance of Substantiating Deductions and the Government's Burden of proving Penalties

Here's a case where pro se tax payers did themselves no favors in tax court lacking documents while providing conflicting excuses for not having them. Generally, deductions are a matter of ...
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Use of Focus Groups to Gauge Impact of Evidence

I attended the legal seminar "Evidence to Win 2018" presented by New York State Trial Lawyers Institute. The speakers were Robert Genes, Nicolas Timko, Larry Simon, Andrew Finklestein, and ...
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