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That figures

Happy new year?

Burdens of proof

  • National Association of Tax Professionals (https://blog.natptax.com/): This week's "You Make the Call" looks at Charles, who was flagged for ID theft by the IRS in 2021. The IRS sent him Letter 5071C and during the validation process asked for the adjusted gross income from his 2021 return and up to two prior years. Charles has yet to file for 2019 and 2020. Is there another way to satisfy the request for prior-year returns while he gets the delinquent ones filed?
  • Global Taxes (https://www.globaltaxes.com/blog.php): Long-term inadequate filing of FBARs lets the IRS loose to pursue fraud — international lack of cooperation and even death notwithstanding, as a recent case shows. 
  • University of Illinois Tax School (https://taxschool.illinois.edu/blog/): This reprint from a UofI workbook looks at the relatively rare occurrence of a Supreme Court rule on a tax matter. At issue is "intentional disregard," a request for a collection due process hearing and a late petition to appeal a finding. Is the 30-day filing deadline under Sec. 6330(d)(1) jurisdictional and unable to be extended?
  • TaxProf Blog (http://taxprof.typepad.com/taxprof_blog/): What's in a name? Plenty, potentially: One inventory item in megastar Kanye West's vast portfolio is his right of publicity, a property interest that represents the commercial value of a celebrity's name, image and likeness. What are the various treatments here?
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