Tax practice

A former Internal Revenue Service agent has pleaded guilty to soliciting a $5,000 bribe from a small business he was auditing.

The Commerce Department's Bureau of Economic Analysis reported that tax rebate checks and economic stimulus payments have boosted personal income, disposable income and personal consumption expenditures significantly since April.

The Senate Finance Committee held hearings on reforming international tax rules, looking at the ways the federal government taxes the foreign income of U.S. taxpayers and businesses.

The Internal Revenue Service has reversed itself on the rolling-average method of valuing inventory and will now consider it valid for tax purposes.

A study by Grant Thornton found that only 843 U.S. corporations out of nearly 10,000 took advantage of a one-time dividend deduction that rewarded them for repatriating their foreign profits, giving them deductions totaling $265 billion.

Internet evangelist Bill Keller is challenging an Internal Revenue Service probe of his organization’s tax-exempt status.

The House passed a bill promising relief for another year from the spread of the alternative minimum tax, but the bill already faces opposition from the White House.

The House Ways and Means Select Revenue Measures Subcommittee held hearings on bills that would encourage employers to automatically enroll their employees in individual retirement account plans.

The Internal Revenue Service is trying to cope with rising gas prices by increasing the optional standard mileage rates that taxpayers can use to calculate the deductible costs of operating an automobile.

The Internal Revenue Service has waived some limitations of the low-income housing tax credit in Indiana and Iowa so that owners of facilities in these states can provide housing to victims of recent storms and flooding.

Questions about economic stimulus payments and tax rebates kept the phones buzzing at Internal Revenue Service offices and cost the IRS a considerable chunk of its budget.

Calculations of economic stimulus payments by the Internal Revenue Service may have been wrong in nearly 400,000 cases.

The Internal Revenue Service said that about 5.2 million retirees and disabled veterans who qualify for economic stimulus payments have not filed to claim the payments.

A former UBS banker, Bradley Birkenfeld, pled guilty to conspiring with an American billionaire real estate developer, Swiss bankers and co-defendant Mario Staggl to help the developer evade paying $7.2 million in taxes by helping him conceal $200 million of assets in Switzerland and Liechtenstein.

Charles Merrill, a self-made millionaire and cousin of the co-founder of Merrill Lynch, could end up serving three years or more in jail for not filing income taxes since beginning a tax protest in 2004.

A judge has ruled against the Internal Revenue Service in a Freedom of Information Act case, telling the agency to stop defying her previous orders and turn over statistical information to an outside researcher.

The House Ways and Means Committee has passed a bill aimed at forestalling the spread of the alternative minimum tax for another year.

The Internal Revenue Service has granted an extension to victims of the Midwest floods so they will have more time to make their quarterly estimated tax payments.

The Research Claims Audit Techniques Guide: Credit for Increasing Research Activities Section 41 just released by the IRS is a great roadmap for practitioners of what to expect on an audit. Although the research credit has not been extended, it is expected to be. This guide issued by the Large and Mid Size Business Division (LMSB-04-0508-030) really shows how IRS will scrutinize research credit refund claims (RC claims), which have been designated a Tier I Issue, which in turn means they are of high strategic importance to LMSB and have significant impact on one or more industries. The guide is particularly geared toward those prepared under the most common approach being used, prepackaged RC claim studies. How those studies are typically done is explained in detail, as well as the potential problems that IRS sees with them. Eustace, T.C. Memo 2001-66, aff’d 312 F.3d 1254 (7th Cir. 2002) is cited as presenting a typical research credit claim involving an accounting firm study and a prepackaged submission. This is an extensive section in the guide on how an auditor should go about evaluating RC study-based claims and specific advice that an information document request (IDR) should be made for the engagement letter from the outside consultant conducting the study. Even the accompanying exhibits have great information, such as a 19-step checklist that the auditor should follow when reviewing the claim, a comprehensive mandatory research credit claims IDR, and even a check sheet to help deal with computational issues. I don’t get excited by every audit technique issued, but this captured my interest because it reminded me of a guide IRS put out a number of years ago on cost segregation. That guide was used by some practitioners as a blueprint on how to successfully conduct a cost segregation study that would withstand IRS review. Both that and the latest guide illustrate that as more professionals utilize studies as significant revenue generators by justifying the fees charged as a small percentage of the tax benefits obtained, IRS will adopt a uniform policy with regard to them. There is a great benefit to this as the audit technique guide is very informative and explains exactly what won’t and will pass IRS muster.

The Internal Revenue Service violated some of its own legal requirements in some of the seizures of taxpayer property it conducted in the past two years, according to a new report.