The IRS’ determinations in a notice of deficiency are generally presumed correct. Therefore, unless specifically excepted by Tax Court Rule or statute, the burden of proof in civil tax proceedings is ordinarily on the taxpayer(s). Last week, the U.S. Tax Court issued a summary opinion sustaining the IRS’ denial of deductions because the taxpayers’ “hodgepodge of receipts” was insufficient to substantiate their claims. Wright v. Comm'r of Internal Revenue, No. 17520-19S (U.S.T.C. Jun. 10, 2024). The IRS examined an S corporation’s 2015 Form 1120-S, U.S. Income Tax Return for an S Corporation, and disallowed a portion of the company’s claimed deductions. Those disallowances resulted in the IRS making positive adjustments to the S corporation’s business income for each year and, consequentially, positive adjustments to the amounts of flow through income reported on the owners’ related Schedule E (i.e., on the owners’ personal income tax return). The Wright case is yet another reminder of the importance of maintaining credible records to ensure transparency and creditability in the production of evidence. https://lnkd.in/evCb8Sam Thank you Michelle E. Espey for this week's Tax Tracker!
Farrell Fritz, P.C.’s Post
More Relevant Posts
-
Understanding the Income Tax Scrutiny Process: A Guide for Taxpayers 📢 Hey Taxpayers! Ever wondered what happens if the tax department finds issues with your returns? We've got you covered! From receiving a notice to appealing to the Income Tax Appellate Tribunal, here's a simple guide to help you understand the assessment process. Stay informed and make sure your taxes are in order! We want to make sure you're clear about how the Income Tax Department assesses your tax returns if they find any discrepancies. Here's a simple guide: 1. Filing Your Tax Return: - You start by filing your tax return with the Income Tax Department. 2. Noticing Discrepancies: - If the tax department spots any issues in your returns, they'll send you a notice to address them. 3. Responding with Documents: - Once you get the notice, it's important to reply quickly and provide all the necessary documents to explain any discrepancies. 4. Final Assessment under Section 143(3): - After reviewing your documents, the tax officer will make a final decision under Section 143(3) about your tax situation: whether you owe tax, are owed a refund, or owe nothing. 5. Appealing to the Commissioner: - If you disagree with the decision under Section 143(3), you can appeal to the Commissioner. 6. Taking It to the Income Tax Appellate Tribunal (ITAT): - If you're still not satisfied after appealing to the Commissioner, you can take your case to the Income Tax Appellate Tribunal (ITAT). If you have any questions or need help with your tax matters, feel free to reach out to us. Best regards, Santosh Patil Founder www.alltaxfin.com 9769201316 #IncomeTax #TaxReturns #TaxAssessment #TaxpayersGuide #ITATAppeal #StayInformed
To view or add a comment, sign in
-
In case you’ve already filed your Income Tax Return, there is always a possibility of getting an Income Tax notice for various reasons. It is essential not to stress if you’ve accurately provided all the necessary details to the Income Tax Department during the filing process. However, if there were any inadvertent errors, it’s advisable to seek guidance from a tax professional to carefully prepare responses to the notice. Hera are seven common types of income tax notices that taxpayers could potentially receive.
To view or add a comment, sign in
-
In case you’ve already filed your Income Tax Return, there is always a possibility of getting an Income Tax notice for various reasons. It is essential not to stress if you’ve accurately provided all the necessary details to the Income Tax Department during the filing process. However, if there were any inadvertent errors, it’s advisable to seek guidance from a tax professional to carefully prepare responses to the notice. Hera are seven common types of income tax notices that taxpayers could potentially receive.
Types of Notice Under Income Tax Act 1961: A Detailed Synopsis
https://anptaxcorp.com
To view or add a comment, sign in
-
Penalty Alert: File Income Tax Returns on Time to Avoid Rs. 5,000 Late Fee even if no Tax is Payable: Under the previous tax slabs, the higher late fees of Rs. 5,000 was applicable only if a taxpayer had tax due and failed to file their income tax return on time. The relevant section, 234F of the Income Tax Act, mandates the fee for late filing of income tax returns. It states:"Without prejudice to the provisions of this Act, where a person required to furnish a return of income under section 139, fails to do so within the time prescribed in sub-section (1) of the said section, he shall pay, by way of a fee, a sum of five thousand rupees. Provided that if the total income of the person does not exceed five lakh rupees, the fee payable under this section shall not exceed one thousand rupees. Under the new tax regime, while no income tax is payable on incomes up to Rs. 7 lakhs, taxpayers earning between Rs. 5 lakhs to Rs. 7 lakhs who have no tax liability will still be subjected to the higher late fee of Rs. 5,000 if they fail to file their returns on time. This adjustment reflects a shift towards imposing a uniform penalty for late filing based on income thresholds rather than linking it solely to tax liabilities. Thus, taxpayers falling within the income range of Rs. 5 lakhs to Rs. 7 lakhs need to ensure timely filing to avoid the increased penalty, even if they do not owe any income tax.
To view or add a comment, sign in
-
-
📢 Attention Tax Professionals and Taxpayers! Valuable Relief in Notice 2024-7 for Failure to Timely Pay Tax for Taxable Years 2020 & 2021 📢 Here are the key points: 🎯 Purpose: Notice 2024-7 provides relief from additions to tax for the failure to pay income tax with respect to certain income tax returns for taxable years 2020 and 2021. 📚 Background: This notice explains the relevant sections of the Internal Revenue Code and when additions to tax may apply. It emphasizes that these additions can be waived under certain circumstances. 🦠 COVID-19 Impact: The relief is connected to the COVID-19 pandemic and the national emergency declaration. It led to the suspension of specific automated reminder notices by the IRS. 🔑 Grant of Relief: Eligible taxpayers who meet specific criteria may qualify for relief, including having an assessed income tax under $100,000 as of December 7, 2023, and receiving an initial balance due notice on or before December 7, 2023. 📝 Eligible Returns: The relief applies to various income tax returns, from individuals to corporations and more. ⏳ Relief Period: The relief period began either when the IRS issued an initial balance due notice or on February 5, 2022, and ends on March 31, 2024. Taxpayers will still be liable for any additions to tax or interest outside of this period. 🚫 Exceptions to Relief: It's crucial to note that the relief does not apply to penalties, interest not specified in the notice, or penalties related to fraud. Certain agreements and judicial proceedings are also exempt. For further details, you can contact Jamie Song of the Office of the Associate Chief Counsel (Procedure and Administration) at (202) 317-6845. This notice provides a valuable opportunity to alleviate tax-related stress. As tax professionals, we should be aware of this relief and ensure eligible taxpayers are informed. If you or your clients meet the criteria, take advantage of this relief. Remember, knowledge is power when it comes to managing your tax obligations! #TaxRelief #IRSNotice #TaxProfessionals #Taxpayers #IRS #CPA #EA
To view or add a comment, sign in
-
This tax calculator was helpful and eye-opening. Beginning 2026, majority of taxpayers will see their tax liability increase if Congress does not extend the TCJA (Tax Jobs and Jobs Act) signed into law in 2017. There are two illustrations this tool will show you: 1. Your projected tax liability if Congress extends TCJA. 2. Your estimated tax liability if Congress does nothing and lets TCJA expire. https://lnkd.in/eubH6jeP ********* It's important to note that this information is general in nature; not tax advice. Consult with your tax professional for specific advice about your current tax situation.
How the TCJA's Expiration Will Affect You
https://taxfoundation.org
To view or add a comment, sign in
-
The Tax Cuts and Jobs Act of 2017’s (TCJA’s) limit on the federal income tax deduction for state and local taxes (SALT) has proven costly for many owners of real estate businesses. However, more than 30 states have now enacted a workaround for pass-through entities (PTEs) that could provide some welcomed tax relief. #realestatelife #realtor #taxes #accounting
Pass-Through Entity Taxes Can Pay Off For Real Estate Firms - ORBA
https://www.orba.com
To view or add a comment, sign in
-
How long do taxpayers need to keep each year’s tax records? Learn about the different periods of limitations that apply to income tax returns to identify which applies to your situation. https://bit.ly/3VO0Qnf
How Long Should Tax Records Be Kept?
https://www.brownplus.com
To view or add a comment, sign in
-
⏰ Q1 Estimated Tax Payment Due April 15 ⏰ Estimated tax payments are primarily for taxpayers whose income isn’t subject to withholding taxes, and it is primarily the taxpayer’s responsibility to determine whether they're required to pay or not (meaning no IRS notices). To understand if you fall in this group and to learn how to make your payment, check out our free resource: https://lnkd.in/gGifdx8Y #tax #taxdeadlines #IRS
How to Make Estimated Tax Payments
https://evolutiontaxlegal.com
To view or add a comment, sign in
-
Starting with the 2023 tax year, certain Massachusetts taxpayers are required to pay a 4% surtax on taxable income in excess of $1 million. This so-called “Millionaires Tax” is imposed on top of the state’s current 5% flat income tax. On December 1, 2023, the Massachusetts Department of Revenue (DOR) issued a set of FAQs to address a number of questions regarding the Millionaires Tax that were not addressed in the enacting legislation. The following is a summary of the DOR guidance on some of the key questions: For the full client alert, please click on the following link: https://lnkd.in/eGY5fUQR
Massachusetts Provides Clarity Regarding Millionaires Tax
cl-law.com
To view or add a comment, sign in
Experienced + Passionate Marketer Creating Organizational Impact 🎯 Director of Marketing & Business Development, Farrell Fritz, P.C.
1moVery interesting, Michelle E. Espey.