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Tax Controversy and Litigation
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For Those Solicited for Tax Saving Schemes, Heed Your Parents’ Advice: If It Sounds Too Good to Be True, It Probably Is!

With the end of the year approaching and tax changes on the horizon for 2018, many business owners and investors are seeking creative ways to minimize their current and future tax burdens.  While some plans are legally sound and others may appear aboveboard, at least on their face, taxpayers should remember the age-old adage: “If…

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Coinbase and the IRS: The Takeaway for Virtual Currency Investors (Comply with Tax Obligations or Face Real Consequences)

On November 28, 2017, a federal judge in California ordered Coinbase, Inc. (“Coinbase”), a major virtual currency exchange, to provide the Internal Revenue Service (“the Service”) with account information for thousands of individuals trading virtual currency through its exchange.  (A copy of the entire Order in United States v. Coinbase, Inc., et al., No. 17-cv-01431-JSC…

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As If! Restitution Order Does Not Permit the IRS to Collect Penalties and Interest without First Assessing a Tax Liability

On October 3, 2017, the United States Tax Court issued an opinion in Klein v. Commissioner, 149 T.C. No. 15,[1] which creates a potential roadblock for the Internal Revenue Service (“the Service”) in civil cases stemming from criminal matters.  In particular, the Tax Court held that the Service cannot use a criminal order of restitution…

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Thread Count and Tax Reform

The term “thread count” refers to the number of horizontal and vertical threads per square inch of fabric.  Per the marketers of bedsheets: the higher the thread count, the softer and more luxurious the product.  Envision how some high thread count sheets would look under a microscope: that is the current tax code.  It is…

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October Tax Filing Extension Deadline Nears

For taxpayers who requested an extension to file their 2016 taxes, the time has come. The deadline for filers who received a six-month extension from the usual April 2017 date is Monday, October 16, but there are a few things to know about filing requirements and additional relief available for those affected by federally-recognized disasters.…

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Evaluating the Impact of Bedrosian

On September 20, 2017, the Eastern District of Pennsylvania issued an important taxpayer-friendly opinion regarding the willfulness standard in FBAR penalty matters.  In Bedrosian v. United States, Case No. 2:15-cv-05853-MMB (E.D. Pa., Sept. 20, 2017), the court held that the government had not met its burden in proving that Bedrosian had willfully violated FBAR reporting…

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Acquiring a Business with Employment Tax Issues: Tips for Avoiding Personal Liability for Taxes

In times of financial crisis, many businesses succumb to financial pressures and “borrow” from employees’ tax withholdings to pay other creditors.  To some, this seems like a viable alternative to meet short-term cash needs, keep the lights on, or service existing debt.  Unfortunately, for many struggling businesses, circumstances never significantly improve and tax withholdings are…

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Deadline Expires for MD Tax Credit Applications for Homeowners, Renters

The September 1st deadline has arrived for homeowners and renters to file applications for Maryland tax credits based on property taxes they have paid. The Homeowner’s Property Tax Credit Program and the Renters’ Tax Credit Program alleviate some of the tax burden for lower income Maryland residents who meet program requirements. Tax relief for Maryland…

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Rosenberg Martin Greenberg

25 South Charles Street, 21st Floor MD 21201
Phone: 410-727-6600
Map & Directions

Rosenberg Martin Greenberg

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