| Life Cycle of a Federal Tax Controversy - JOURNAL OF TAX PRACTICE & PROCEDURE December 2006 - January 2007 | |
| Reprinted with the publisher’s permission from the JOURNAL OF TAX PRACTICE & PROCEDURE | |
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| Life Cycle of a Federal Tax Controversy - Maryland Bar Journal November 2006 | |
| Reproduced with the permission of the Maryland Bar Journal | |
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| Recent Tax Initiaves | |
| The updated estimate of the overall gross tax gap for Tax Year 2001 is now $290 billion. Over 80% is from underreported taxes. Since 2001, the IRS increased its enforcement revenues from $33.8 billion in 2001 to $47.3 billion in 2005. Further audits of taxpayers earning $100,000+ topped 221,000 in fiscal year 2005. | |
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| Making Your Tax Case Before IRS Appeals | |
| There can be no doubt that the IRS is revitalizing its collection efforts. From our prior newsletter, the Robinette opinion was decided by the 8th Circuit only a few weeks ago. It touched on a theme becoming more prevalent among the tax community: making the administrative record while looking to the statute of limitations. | |
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| Section of Taxation | |
| On Tuesday, February 28th, the 9th Circuit published its decision in Commissioner v. Ewing, 2006 WL 463788 (9th Cir.). Ewing deals with the denial of an innocent spouse claim where the couple was still married, and the wife believed the husband would be satisfying 'his share' of the self-assessed tax liability. The ruling identifies... | |
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Kundra & Associates, with its primary office located in Rockville, Maryland, advises and defends individual and business clients in tax controversies and tax litigation with the IRS and state and local tax authorities. The firm represents American citizens living abroad, as well as local and national clients in Maryland, Virginia, and Washington, DC, in communities such as Bethesda, Frederick, Baltimore, Ellicott City, Annapolis, Gaithersburg, Upper Marlboro, Potomac, Germantown, Montgomery Village, Columbia, Silver Spring, Catonsville, Elkridge, Glen Burnie, Pikesville, Towsen, Cockeysville, Westminster, Taneytown, Thurmont, Myersville, Hagerstown, Arlington, McLean, Alexandria, Annandale, Springfield, Fairfax, Reston, and other communities in Montgomery County, Howard County, Baltimore County, Anne Arundel County, and Prince George’s County.The firm also represents clients internationally in countries such as the United Kingdom, France, India, Canada, Africa, Cyprus, Lebanon, Belgium, Italy, Israel, Mexico, Ghana, Nigeria, Venuzuela, Columbia, Zimbabwe, South Africa, China, Pakistan, Afganistan, Indonesia, Bahamas and the Caymen Islands.
Kundra & Associates Tax Attorneys
110 North Washington Street
Suite 406
Rockville, MD 20850
Phone: (301) 424-7585
Fax: (301) 424-7047