Tax Controversy Services

On June 12, 2013, the Treasury Inspector General for Tax Administration (“TIGTA”) released a report reviewing IRS compliance with legal guidelines when conducting seizures of taxpayers’ property during a fiscal year period ending June 30, 2012.  TIGTA reviewed a random sample of 50 of the 738 seizures that occurred during the fiscal year ending June…

In a report issued in June, the Treasury Inspector General for Tax Administration (“TIGTA”) found that employers continue to mis-classify employees as independent contractors even after rulings by the I.R.S. . Employers are responsible for one half of the Social Security, Medicare, and Unemployment taxes (1.45% for Medicare, 4.2% in wage withholding, and an additional…

In a Treasury Notes Blog Post on July 2, 2013, Assistant Secretary for Tax Policy, Mark J. Mazur, announced that enforcement of the employer mandate portion of the Affordable Care Act would be delayed until 2015. The employer mandate – officially known as the Employer Shared Responsibility Payment – applies to “large employers” – those…

John Dies is a director, Jeremy Fingeret is a senior managing director, and Scott Weese is an associate in the Tax Controversy Services Department of alliantgroup LLP. Contrary to early concerns, the recent Second Circuit opinion in Union Carbide Corp. (UCC II) merely reinforces the status quo allowing taxpayers to claim any supply cost for…

In response to a letter from Senator Kay Hutchinson, the I.R.S. Associate Chief Counsel for Passthroughs and Special Entities, Curt Wilson, acknowledged that current guidance pertaining the carbon dioxide sequestration credit, contained in Notice 2009-83, ignores what Hutchinson considers to be a crucial element of the credit’s Congressional intent. Specifically, the Notice defines an “industrial…