The IRS Summons

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To determine if an individual (or entity) is compliant with the tax laws, the IRS has broad powers to conduct examinations and investigations. According to Internal Revenue Code 7602(a)(1), the IRS may examine a number of sources (e.g. records or data) to determine the accuracy of a tax return or tax liability and for tax…

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Kovel Letters

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On a typical business day, a couple of IRS special agents (i.e. criminal investigations) showed up at a taxpayer’s house. You know you are in the presence of an IRS special agent if you see a badge and a gun. The taxpayer immediately begins to ask the reason for the IRS special agents’ visit. The…

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IRS Audits and Criminal Tax Matters

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Many taxpayers who receive an examination (“audit”) notice from the IRS often are concerned whether “they could go to jail.” Indeed, problems originate with the tax return as a result of errors or fraud. The courts have long since opined connecting the audit to criminal tax convictions. In a Ninth Circuit opinion case, United States…

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NIL Deals and Taxes

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The landscape of college football, basketball, and athletics in general has changed. As a result of a recent Supreme Court decision against the NCAA (NCAA vs. Alston) and subsequent NCAA rule changes, athletes are now able to make money on their Name, Image, and Likeness (“NIL”). This was long overdue. I recall my time as…

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The Right To Retain Representation

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Don’t get it twisted! Taxpayers, you have a right to retain a representative to assist you in your IRS matters. The taxpayer bill of rights states “[t]axpayers have the right to retain an authorized representative of their choice to represent them in their dealings with the IRS. Taxpayers have the right to seek assistance from…

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