Paul L. Caron
Dean
Pepperdine Caruso
School of Law
IRS News
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IRS Releases 2006 Enforcement Stats
The IRS has released Fiscal Year 2006 Tax Enforcement Statistics: Statement of IRS Commissioner Mark W. Everson Fiscal Year 2006 Enforcement Statistics Fiscal Year 2006 Enforcement Statistical Charts
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Posner Slams IRS’s “Pathetic” Position in Mexican Debt-Equity Swap Case
Judge Posner has some harsh words about the Service’s position in a panel opinion issued today, Kohler Co. v. United States, No. 05-4472 (7th Cir. 11/20/06): In 1986, Kohler decided to build a plant in Mexico that it estimated would cost at least $29 million. It needed pesos in order to pay for land, building
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IRS Announces Telephone Tax Refund Formula for Businesses & Nonprofits
The IRS yesterday announced (IR-2006-179) a formula that will allow businesses and tax-exempt organizations to estimate their federal telephone excise tax refunds. “The formula will provide a less burdensome option than gathering up to 41 months of old phone records,” said IRS Commissioner Mark W. Everson: Businesses and tax-exempt organizations can figure their refund amounts
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Does the IRS Owe You Money?
The IRS announced today (IR-2006-178) that it is holding refund checks totaling $92.2 million for 95,476 taxpayers (an average of $963 per taxpayer) whose checks could not be delivered: Taxpayers can use the "Where’s My Refund?" feature on the home page of the IRS.gov Web site to learn the status of their refunds. To use
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Treasury Issues New Model Income Tax Treaty & Technical Explanation
The Treasury Department has issued (HP-168) new versions of the U.S. Model Income Tax Convention and Model Technical Explanation: The U.S. Model Income Tax Convention is used as a starting point in bilateral treaty negotiations with other countries. The Model Technical Explanation will serve as the basis for technical explanations of bilateral tax treaties based
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IRS Announces 2007 Inflation Adjustments
The IRS today announced (IR-2006-173) inflation adjustments to take effect for 2007, including: The personal and dependency exemption will increase to $3,400 (up $100 from 2006) The standard deduction will increase to $10,700 for married couples filing a joint return (up $400) and $5,350 for singles (up $200) Tax-bracket thresholds will increase for each filing
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WSJ: Delays in Processing Tax-Exempt Applications
Interesting article in today’s Wall Street Journal: IRS Is Taking Longer to Clear Tax-Exemption Applications, by Tom Herman: You may need an extra dose of patience these days if you’re waiting for the Internal Revenue Service to approve your organization’s application for tax-exempt status. In a recent statement, the IRS said "many" organizations and tax
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NYSBA on Treasury’s Authority to Issue Regulations
The New York State Bar Association Tax Section has released a letter and report sent to the Treasury Department and the IRS on The Authority of the Treasury Department and the IRS to Issue Regulations Under the IRC: The Report discusses grants of authority given by Congress to the Treasury Department and the IRS to
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Grassley & Baucus Criticize IRS’s Handling of Free File Program
Senate Finance Committee Chairman Charles Grassley and Ranking Member Max Baucus have issued a joint letter to IRS Commissioner Everson and press release expressing concern that the IRS continues to make the Free File program "inaccessible, complicated, and otherwise frustrating for taxpayers" “It seems the tax preparation industry was holding all the cards in the
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IRS Is Looking to Hire Special Agents
From IRS Careers: The IRS is seeking potential applicants to join our elite and diverse workforce as a Criminal Investigator (Special Agent). IRS special agent, GS-1811-5/7/9, positions will open nationwide (includes Puerto Rico) on November 13, 2006. If you are searching for an exciting career in law enforcement and have strong accounting and communications skills,
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2007 Standard Mileage Rates
The IRS has announced (IR-2006-168) the publication of the 2007 Standard Mileage Rates in Rev. Proc. 2006-49. Beginning Jan. 1, 2007, the standard mileage rates for the use of a car (including vans, pickups or panel trucks) will be: 48.5 cents per mile for business miles driven (up from the 44.5 cents per mile rate
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IRS Pushes Back Availability of 2006 Tax Forms
The IRS has posted a Tax Products Posting Schedule, which lists publication dates for various IRS instructions, forms, and publications. Senator Baucus’s office issued a press release critical of the delay in the release of these materials: Senator Baucus noted repeatedly this year that congressional delays in renewing a number of expired or expiring tax
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Politics and the IRS
Wednesday: Commissioner Mark Everson announces that the IRS will postpone collection activities against taxpayers in areas struck by Hurricane Katrina until next year. (A one-year extension of filing deadlines expired October 16.) Thursday: David Cay Johnston reports in the New York Times (I.R.S. Going Slow Before Election) that four former IRS commissioners (Donald Alexander, Sheldon
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Stanford Gets IRS Ruling Permitting Trust Investments in its Endowment
Stanford announced this week that it has obtained a private ruling from the IRS that will lift tax barriers that have prevented it from investing charitable trusts established by donors with the larger university endowment. To date, Harvard is the only U.S. university to have been granted this special permission. From the Chronicle of Higher
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Treasury Department Seeks to Hire Ethics Attorney
The Treasury Department is looking to hire an Ethics Attorney Major Duties: The incumbent provides legal advice primarily concerning ethics and the Hatch Act to officials at all levels within the Departmental Offices. In addition, may be asked to provide legal advice regarding labor relations, procurement, FOIA, personnel, appropriations and other legal issues concerning agency
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SOI Releases Special Studies in Federal Tax Statistics
The Statistics of Income Division has released Special Studies in Federal Tax Statistics: Selected papers given in 2005 at the annual meetings of the American Statistical Association and the National Tax Association have been included in a recent edition of Special Studies in Federal Tax Statistics . . . . The papers are organized into
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IRS Provides Guidance on Qualified Appraisals for Noncash Charitable Contributions
The IRS today issued Notice 2006-96, 2006-46 I.R.B. ___ (11/13/06), which: provides transitional guidance on the new definitions of “qualified appraisal” and “qualified appraiser” in § 170(f)(11) for purposes of substantiating deductions for charitable contributions of property; and provides guidance on complying with new § 6695A, regarding penalties for appraisals that result in substantial or
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IRS Announces 2007 Pension Contribution Limits
The IRS today announced (IR-2006-1620) the 2007 pension contribution limits: 401(k)/403(b) Elective Deferral Limit (402(g)(1)): $15,500 Government/Tax Exempts Deferral Limit (457(e)(15)): $15,500 Catch-up Contribution Limit: $5,000 Annual Compensation Limit: $225,000 Highly Compensated Employee Limit: $100,000 Key Employee Officer Compensation: $145,000 Maximum Annual Benefit: Defined Benefit Plan: $180,000 Maximum Annual Contribution: Defined Contribution Plan: $45,000 SEP
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New Regs to Tax Gain on Exchange of Appreciated Property for Annuities
The Treasury Department and IRS yesterday issued proposed regulations addressing the tax treatment of an exchange of property for an annuity contract. The same rule s apply to exchanges for both private annuities and commercial annuities. From IR-2006-161: A decades-old IRS ruling generally postpones tax on the exchange of appreciated property for a private annuity,
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Wesley Snipes Indicted on Tax Fraud Charges After Seeking $12 Million Tax Refund
Actor Wesley Snipes was indicted today on tax fraud charges after seeking $12 million in tax refunds and failing to file returns for six years. From the U.S. Attorney’s press release: An eight-count indictment was unsealed today charging Wesley Trent Snipes, formerly of Windermere, Fla., Eddie Ray Kahn, of Sorrento, Fla., and Douglas P. Rosile,
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Tax Revolt: Plaintiffs File Coordinated Cases Against IRS
Interesting article in today’s Legal Times: Tax Revolt: Plaintiffs File Coordinated Cases Against IRS, by Emma Schwartz: Michael Stephens hates the IRS. He believes it steals his money, and he won’t stand for it. "That’s all we are, is slaves," says the 49-year-old truck driver from Georgia, who sued the agency. He claims he is
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The IRS and Moneyball
In my other blogging gig on MoneyLaw, I followed up on Tuesday’s post on the the IRS’s recruitment of new lawyers by asking Is the IRS Applying Moneyball Principles in its Hiring of Law Students?: Would the IRS be better served recruiting students at the top of the class at a non-elite school rather than
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More on IRS Hiring of Law Students
Following up on yesterday’s post on the IRS’s ramped up efforts at recuiting the best and the brightest law students: Bryan Camp (Texas Tech) shares with us his IRS hiring story: The story of how I went to work for the IRS Office of Chief Counsel is a beautiful story of bureacratic hiring practices. After
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WSJ on IRS Recruitment of Law Students
Interesting article in today’s Wall Street Journal: It’s Taxing to Recruit Top Law Grads to IRS, But a New Push Betters Returns, by Robert Guy Matthews: Donald Korb, chief counsel of the IRSe, sits in a high-back chair in a meeting room lined with law books and prepares to talk to a small gathering of
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IRS Reduces Tax on Housing for U.S. Expatriates
The IRS has issued Notice 2006 -87, 2006-47 I.R.B. (Oct. 23, 2006). As explained in the Treasury Department’s press release (HP-133): The Treasury Department and IRS issued Notice 2006-87 today, which permits individuals who work outside the U.S. and live in foreign countries with high housing costs to deduct or exclude a greater portion of