Some things in life are simply no-brainers, not only because the justification for doing them is so immediately obvious, but further, because the justification for not doing them is so obviously absent. The filing of “protective” claims for refund as a hedge against the draconian provisions th...

Federal tax liens are among the IRS’s most powerful tools to secure payment of delinquent taxes. These liens attach broadly to the taxpayer’s property and rights to property, creating significant legal and financial implications.

This article examines the various types of pr...

As a taxpayer with unpaid tax claims, it’s crucial to understand the concept of federal tax liens and how they can impact your financial situation. This article is the first in a series that will provide you with essential information about tax liens, including what they are, how they ar...

In 2024, a major regulatory change is taking place for small businesses and corporations across the United States. The Corporate Transparency Act (CTA), administered by the Financial Crimes Enforcement Network (FinCEN), introduces Beneficial Ownership Informatio...

In United States v. Warfield (In re Tillman), No. 21-16034 (9^th Cir. 2022) the Ninth Circuit reversed the lower courts and determined that the chapter 7 trustee could not avoid the federal tax lien on the debtor’s homestead.

In Tillman, the debtor purchased a house in Prescot...

To begin, IRC § 6511(a) provides that the statute of limitations period for filing a claim for credit or refund generally expires two years after paying the tax or three years after filing the return, whichever is later. In addition, the actual amount a taxpaye...

IRC 6751(b) requires supervisory approval in writing before the assessment of certain penalties under the Internal Revenue Code. It was enacted as part of the 1998 Restructuring and Reform Act to combat the leverage IRS Agents held over taxpayers with their ability to impose penalties withou...