Tax Controversy and Litigation
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Tax Deductions for Small Business Owners

Small business owners make up the bulk of American businesses. According to the Small Business Administration, in 2010, there were nearly 28 million small businesses, making up 99.7% of U.S. employer firms. More than 50% of the small businesses were home-based, and nearly 75% were sole proprietors. The vast majority of Maryland businesses, then, can…

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The Business Tax Audit: Risks and Consequences

At best, a business tax audit will consume only time and personnel resources. At worst, you and your business could face criminal charges and payments of additional taxes, fines, and penalties. Moreover, if the audit uncovers fraudulent activity, substantial underpayments of taxes, or unreported income an audit can be expanded from three to six years,…

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To File Jointly? Or Separately? Considerations for Married Couples in Maryland

For married couples who reside in Maryland, the question of whether to file taxes jointly or separately can be a burdensome task. Many people assume that joint filing is expected or more advantageous, but the interaction of federal and state tax laws can complicate the decision. Baltimore-based tax law firm Rosenberg Martin Greenberg can help…

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Colliot and Its Effect on Penalties for Potential FBAR Violations: Ruling Provides for Significant Limitation on Amount of Penalties

On May 15, 2018, the United States District Court for the Western District of Texas issued an important ruling concerning the application of willful FBAR penalties under 31 U.S.C. § 5321.  In United States v. Colliot, Case No. AU-16-CA-01281-SS (W.D. Tex. 2018), the court held that the Internal Revenue Service (“the Service”) could not assess…

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Responding to an IRS Letter 5935 and IRS Form 15023: What to Do (and Not Do) to Resolve Your Offshore Tax Issues

In recent months, the Internal Revenue Service (“the Service”) began the process of issuing follow-up letters to taxpayers who either requested preclearance to participate in the Offshore Voluntary Disclosure Program (“OVDP”) or who submitted a voluntary disclosure letter within the OVDP.  For those that receive these letters – IRS Letter 5935 and IRS Form 15023…

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Planning to Travel Abroad? Don’t Let the IRS Stop You at the Border. Understanding Recent Guidance Regarding Passport Revocation Rules Under I.R.C. § 7345

As part of the Fixing America’s Surface Transportation Act (“FAST Act”) of 2015, Congress mandated that the State Department deny any passport application for an individual, or revoke any previously issued passport for an individual, if the Internal Revenue Service (“the Service”) certifies that the individual has a “seriously delinquent tax debt.”  In early 2018,…

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Reporting Cryptocurrency Gains and Hard Forks

Due to the inherent structure of cryptocurrency trading most users consider their transactions completely anonymous. The Internal Revenue Service (“IRS”) estimates three million individuals transact in cryptocurrency each year. However, only about 800 to 900 people disclose the capital gains on their Federal Income Tax Returns. Due to the lack of disclosure, in November of…

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Faster, Higher, Stronger, and Tax-Free

Winning a medal at the Olympic Games comes with a number of benefits: the adulation of millions, appearances on late night talk shows and reality TV shows, lucrative endorsement contracts, and until recently, substantial federal and state tax bills. In addition to gold, silver, and bronze medals (which are worth up to approximately $600), Team…

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Continuing an Annual Trend, Comptroller Opens Tax Season by Suspending Tax Preparers

On February 2, 2018, the Comptroller issued a press release announcing that he has suspended the processing of electronic tax returns for nine additional tax preparers.  A copy of the press release can be found here.)  The Comptroller acknowledged that these preparers were suspended based upon technology designed to spot instances of fraud used by…

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Rosenberg Martin Greenberg

25 South Charles Street, 21st Floor MD 21201
Phone: 410-727-6600
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Rosenberg Martin Greenberg

705 Melvin Avenue Annapolis, MD 21401
Phone: 410-727-6600
Map & Directions