Los Angeles California Tax Attorney Blog

IRS Criminal Tax Prosecution- IRS Summons Defense

Los Angeles Tax Attorney - The Internal Revenue Service may issue a summons inquiring “any offense connected into the administration or enforcement of the IRS tax code. Thus, unless there has been a referral to the Justice Department for criminal tax prosecution, that fact that there is a IRS criminal tax aspect to the Internal Revenue Service’s investigation into the taxpayer’s tax returns is not sufficient to quash a IRS tax summons.

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Posted In: FRAUD & CRIMINAL TAX

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IRS Criminal Tax and IRS Tax Fraud - Criminal Tax Defense

California Tax Attorney - A taxpayer may utilize his privilege against self-incrimination in an IRS tax audit as to records in his possession. The IRS tax attorney-client privilege also applies in the IRS tax audit context.

The constitutional immunity against self-incrimination may be involved in an IRS tax audit or tax examination. It also applies during any IRS tax collection activity. The Internal Revenue Service’s announcement policy is that the IRS Criminal Investigation Division’s Special Agent is to advise the taxpayer at the initial meeting that he cannot be compelled to incriminate himself by answering questions or producing documents, even though the case has not yet reached the IRS tax criminal prosecution stage. This does not mean, however, that the taxpayer is protected merely because the IRS agent does not comply with that directive.

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Posted In: FRAUD & CRIMINAL TAX

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Los Angeles IRS Tax Audit for Foreign Income Tax Attorney

Los Angeles Tax Attorney - Many IRS taxpayers located in Los Angles and California have taxable income from foreign sources. IRS is a member of an international tax enforcement and collection program to provide comprehensive IRS tax audit of returns of domestic taxpayers engaged in substantial international activities. IRS district tax directors in Los Angeles, Orange, San Diego, San Francisco, Pasadena, Glendale, Irvine, Torrance and Long Beach have jurisdiction of IRS tax returns audited, while agents of the Office of International Operations provide specialized assistance and participate with the IRS district tax agents in examination.

If a California IRS taxpayer who receives a request to produce foreign-based documents relevant or material to the tax treatment of an examined item fails to comply within 90 days, the requested material may be held inadmissable as evidence in IRS tax court. This rules does not apply if the taxpayer shows reasonable cause for failure to produce the documents.

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Posted In: TAX AUDIT

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IRS Tax Notice to Taxpayer for IRS Summons

Los Angeles Tax Attorney- The IRS tax code states that the summons “shall provide such other information [ apart from the name of the taxpayer] as will enable the person summoned to locate the records required under the summons. If the third party is a designated record keeper, the taxpayer may move in court to quash the summons. Nevertheless, the record keeper is to proceed to assemble the summoned records upon receipt of the summons and be prepared to produce the on the date specified for their examination. A record keeper is entitled to reimbursement for its costs, regardless of whether the summons is enforced.

Los Angeles, Pasadena, Long Beach, Torrance, Orange and Riverside area taxpayers who have been contacted by IRS Tax Summons should contact IRS tax attorney to resolve their tax problems.

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Posted In: TAX AUDIT

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Los Angeles IRS Tax Audit - Tax Attorney Production of Internal Revenue Service Documents

California Tax Attorney - During the coarse of an IRS tax audit, the IRS taxpayer may request documents from the Internal Revenue Service. Under a specific statute, the IRS taxpayer is entitled to inspect his IRS tax return, including amendments, supplements, and attachments.

In addition, Los Angeles, Long Beach, Torrance, Orange, Riverside, San Jose, California taxpayers may force the Internal Revenue Service to produce its manuals of instructions for revenue and special agents, since these are relevant to the possible improper use of the summons to aid an IRS criminal prosecution or IRS tax fraud; the IRS manuals may not be suppressed as privilege. The manuals are not exempt from disclosure under the Freedom of Information Act.

The Internal Revenue Service has been required under the Freedom of Information Act to give the taxpayer access the documents reflecting final opinions that showed how it arrived at certain fair market valuations, against the Internal Revenue Service’s argument that it was impossible to know what information might indirectly identify other taxpayers. But the taxpayer was not entitled to disclosure of a document prepared by the Internal Revenue Service which contained information almost completely derived from audits of another individual where the court found the material to be return information, not subject to the provisions of Freedom of Information Act.

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Posted In: FRAUD & CRIMINAL TAX , TAX AUDIT

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California IRS Offices to Contact Third Parties for IRS Tax Audit and IRS Tax Collection

Los Angeles Tax Attorney - In 1998, the Congress amended Code Section 7602 to prohibit Internal Revenue Service employees including IRS Agents and IRS Auditors from contacting third parties with respect to the taxpayer’s IRS tax liability without providing reasonable advance notice to the taxpayer that third-party contacts may be made.

Most IRS tax attorneys and tax lawyers who resolve tax problems were concerned that (1) that such contacts by the IRS may have negative effect on the taxpayer’s business and could damage the IRS taxpayer’s reputation in the community, and (2) that taxpayers should have the opportunity to resolve his tax problems through his tax attorney before the IRS contacted third parties.

IRS third party contact notice provides a general tax notice to the taxpayer before most third-party contacts are made, and then to periodically (or upon the taxpayer’s request) provide the taxpayer with a record of the persons contacted by the Internal Revenue Service. If you are a taxpayer located in Los Angles or California with IRS tax problems, IRS tax audit or IRS tax levy collection, make sure you contact IRS tax attorney so that your IRS tax rights are protected.

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Posted In: TAX & PENALTIES , TAX AUDIT , TAX PROBLEMS

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IRS Tax Savings for Los Angles and California Businesses and Taxpayers:

Los Angeles Tax Attorney — The Internal Revenue Service released additional information today about the upcoming economic stimulus payments in a specially designed section for Los Angeles and California IRS taxpayers.

Most IRS taxpayers just need to file a 2007 tax return in order to automatically receive the stimulus payment.

Internal Revenue Service provides extensive set of information for all taxpayers with questions about the IRS tax stimulus payments, commonly referred to as rebates. The questions and answers include important information for low-income workers and certain recipients of Social Security, Railroad Retirement benefits and veterans’ benefits.

IRS also provides extensive examples of how much Los Angles, Orange, Long Beach, Torrance, Woodland Hills, Pasadena, Sherman Oaks taxpayers can expect to receive in tax stimulus payments. The page includes more than two-dozen payment scenarios affecting different types of taxpayers.

Continue reading " IRS Tax Savings for Los Angles and California Business and Taxpayers " »

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Posted In: TAX PROBLEMS

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Los Angeles Tax Attorney — The Internal Revenue Service is seeking candidates for membership on the Electronic Tax Administration Advisory Committee (ETAAC). Tax Attorneys, Lawyers and tax problem specialists in the Los Angeles and California area are encouraged to apply.

The IRS will require a federal IRS tax check waiver and criminal or fraud investigation clearance by the IRS and Federal Bureau of Investigation (FBI).

IRS provides an organized public forum for discussion of electronic IRS tax administration issues in support of the overriding goal that paperless filing should be the preferred and most convenient method of filing tax and information returns. ETAAC provides an annual report to Congress on IRS’s progress in increasing electronic transactions. Los Angeles, Orange, Riverside, San Diego, San Jose and San Francisco based IRS taxpayers have one of the nations highest rate of electronic filers.

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Posted In: TAX ATTORNEY NEWS

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As the housing market and the mortgage businesses continue to crumble, even the once wealthy mortgage lenders are facing tax problems. Los Angeles Tax Problems for Mortgage Brokers With the wave of recent foreclosure filings and bankruptcy filings in Los Angeles, Long Beach, Pasadena, Torrance and other areas of Los Angeles County, home prices may continue to deteriorate.

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Posted In: BANKRUPTCY , TAX PROBLEMS

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Los Angles Bankruptcy Attorney - As Los Angles area bankruptcy and foreclosures sky rocket, the Bush administration and Congress are considering new proposals for the government to rescue hundreds of thousands of homeowners whose mortgages are higher than the value of their houses.

Los Angles Bankruptcy Attorneys have noticed many high income neighborhoods in the Los Angeles are facing negative equity position in their homes.

Not since the Depression has a larger share of Americans owed more on their homes than they are worth. With the collapse of the housing boom, nearly 8.8 million homeowners, or 10.3 percent of the total, may lose their homes.

Bush Administration officials say they still oppose any taxpayer bailout for either people who borrowed more than they could afford or banks that made foolish loans during the height of the speculative bubble in housing. This includes majority of Los Angeles homebuyers who bought homes since 2001. In addition, sorting who can be helped and who will not be helped is a daunting task.

Troubled homeowner and their increasing nervousness is evident across Los Angeles, Long Beach, Irvine, Orange, Santa Ana, San Diego, Torrance, Pasadena homeowners where falling home prices and negative equity are increasingly common.

As Los Angles home prices fall, many file Chapter 13 bankruptcy to protect losing their homes through foreclosure. However, with the current bankruptcy code, it is difficult to save many homes in the Los Angeles area.

The Federal Housing Administration, meanwhile, is examining ways to expand its new insurance program, known as FHA Secure, to help people replace their costly subprime mortgages with federally guaranteed fixed-rate mortgages. However, for those in foreclosure now, it may be too late. Mortgage industry executives say that the F.H.A.’s eligibility requirements are too restrictive. In that regard, many Californians including those in Los Angles, Long Beach, Santa Monica, Torrance, El Monte, Pasadena are filing Chapter 13 Bankruptcy petitions to save their homes.

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Posted In: BANKRUPTCY

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IRS Tax Savings for Los Angeles and California Taxpayers

Los Angeles Tax Attorney — Internal Revenue Service allows tax savings to businesses located in Los Angeles, Orange, Riverside, San Diego and San Francisco area businesses. IRS tax savings and incentives include a special 50-percent depreciation tax allowance for 2008 purchases and an increase in the small business expensing limitation for tax years beginning in 2008. For specific details relevant to your business, please contact your Los Angles Tax Attorney.

Continue reading " IRS Tax Savings for Los Angeles and California Taxpayers " »

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A bill introduced in the U.S. Senate last night will change the bankruptcy law to allow Los Angeles Bankruptcy Court Judges and Los Angeles Bankruptcy Attorneys to modify loans held by Los Angeles homeowners on the verge of losing their homes in Los Angeles and California through foreclosure.

The amendment to Bankruptcy Law, S.2636, allows Los Angeles Bankruptcy and Tax Attorneys to provide modifications to mortgage loans on the Los Angeles homewoners' “principal residence” who meet certain income and expense criteria.
Los Angeles Bankruptcy Court May Stop Foreclosure by Modifying Home Loans

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Posted In: BANKRUPTCY

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IRS Tax Court Denies IRS Offer in Compromise

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Posted In: OFFER IN COMPROMISE

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IRS Tax Attorney says IRS Tax Audit for Los Angeles and California Residents will increase.

IRS, including the IRS offices in Los Angeles and throughout California, is likely to get higher budget for tax collection enforcement activities according to the Internal Revenue Service. Tax attorneys and advisors to the President have stated that Congress will appropriate over 11 Billion dollars for IRS. A large portion of the IRS budget will be dedicated towards IRS’ expenditure for tax collection enforcement.

In addition, IRS plans to increase tax audits for higher wealth individuals including taxpayers in Los Angeles, Orange and Riverside County earning $100,000 or more, and especially among those making $1 million plus. The number of IRS tax audits among the million dollar group in Los Angeles and metro California regions increased 84 percent in 2007 from the prior year.

Also, IRS tax proposals include increased criminal penalties for those who have failed to file IRS Income tax returns. New IRS tax proposal will elevate failure to file IRS tax returns from a misdemeanor to a felony. This proposal would be effective for returns to be filed on or after Jan. 1, 2009.

If you haven’t filed your IRS tax return, it might be a good idea to get some help from IRS tax attorney soon.

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Posted In: TAX AUDIT

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IRS Tax and Penalty Collection to increase in Los Angeles and California metro regions.

IRS Tax Attorneys and lawmakers advising Congress are likely to endorse giving Internal Revenue Service more tools to improve IRS tax debt collection, compliance and boost revenue.
Internal Revenue Service faces congressional pressure collect additional $290 billion per year in taxes which go uncollected each year.

Los Angeles and California based IRS centers have been increasing support staff trained for IRS tax collection and audits over the last three years. IRS and the government concurs that collecting additional tax, interest and tax penalties from those who already owe IRS taxes is seen as a smarter move than raising new taxes or tax penalties.

If the president's proposals pass, it would require that brokerage houses and mutual funds to report to the Internal Revenue Service monies invested by taxpayers into various securities. Currently, taxpayer or brokerage houses are not required to report to the Internal Revenue Service such investment records. IRS estimates that if the new tax proposal passes, IRS would raise additional 7.5 billion dollars from 2008 through 2018. “President’s new tax proposal has high level of support from both houses of Congress and is likely to pass this Congressional term,” said tax attorney Victor Yoo, Los Angeles tax attorney with Tax Lawyers Group, APC.

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Posted In: TAX & PENALTIES , TAX PROBLEMS

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As the housing prices gradually decline in the Los Angeles area, foreclosure and bankruptcy attorneys in the Los Angeles area have been inundated with inquiries by consumers desperate to save their homes.

Los Angeles Times is reporting that to help homeowners, six of the largest U.S. mortgage lenders, including Los Angeles based Countrywide, announced today they will halt the foreclosure process while they try to work out a new payment scheme with the delinquent borrowers. This new plan is dubbed "Project Lifeline," and set to identify borrowers more than 60 days delinquent and stall any foreclosure proceedings by much as 30 days while new loan terms may be negotiated.

This "new" plan is not really new. Most banks have been extending additional grace period beyond the statutory foreclosure timelines to accommodate delinquent home owners. In this market, most banks do not want to foreclose on the homeowner. If you can show any reasonable cause or provide a plan which can demonstrate your ability to catch up on your arrears, most lenders have been holding off the foreclosure process in some cases as much as 6 months.

The real plan to stave off home foreclosures must involve lowering the interest rates and providing homeowners with a traditional 30 year loan. All these save the "American Dream" plans I've seen are gimmicky at best...its like trying to fix a broken dam with playdoh.

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Posted In: BANKRUPTCY

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Los Angeles has one of the nation’s highest number of self employed or small business operations. IRS is increasing its enforcement and compliance activities with respect to these taxpayers. IRS Tax Audits overall have increased every year over the last three years. IRS targets many of these businesses which its believes are involved in high cash volume business including the garment, restaurant, travel, tour and numerous other service related sectors where compliance and reporting requirements may be lacking.

In addition, IRS will continue to monitor single cash transactions involving more than $10,000.00. The Tax Reform Act of 1984 required businesses that receive large cash payments to report them to the Internal Revenue Service. The statute was designed to help the Service “identify taxpayers with large cash incomes.” In addition, the Patriots Act and other collateral legislation allows increased surveillance on transfer of funds including cash. A bank or a business who in the coarse of his trade or business is paid more than $10,000 in cash in one or more related transactions must file a return with the Service. It is common that such filings would trigger an IRS Audit or investigation.

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Posted In: TAX PROBLEMS

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