While the IRS uses the mitigation provisions of I.R.C. §§ 1311-1314 to reopen a taxpayer’s closed tax year and assesses tax deficiencies, it hardly facilitates taxpayers in using these provisions in similar fashion when seeking a refund from a closed…
Not knowing the details of a business transaction sounds preposterous on its face, especially when the ignorant taxpayer is the party which formulated the transaction. In the case of Makric Enterprises, Inc. v. Commissioner, TC Memo 2016-44, a failure to make…
Federal tax law provides the foreign tax credit to relieve taxpayers of the double tax burden imposed when their foreign income is taxed by both the United States and the foreign country where their income originated. Usually, if the foreign…
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At Thorgood Law Firm in New York, we are IRS attorneys dedicated to bringing legal counsel to taxpayers across the United States.
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