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Is a Retirement Account E…

Is a Retirement Account Early Withdrawal Tax Penalty Unconstitutional Discrimination?

May 26th, 2020
Posted By
Joseph R. Viola
What’s the difference between a tax-advantaged retirement account and a regular savings account? About 10% if you take a withdrawal too early. But could that early withdrawal tax penalty be unconstitutional age or disability discrimination? The U.S… Read More
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Categories: Tax / IRS Penalties, Tax Tips for Professionals
Court Says Taxpayer Could…

Court Says Taxpayer Could Not Redeem Real Estate Sold Under Tax Lien

May 11th, 2020
Posted By
Joseph R. Viola
Taxpayers who sink their assets into real estate rather than pay their taxes can find themselves facing sheriff sales when the IRS comes to collect what is owed. One taxpayer tried to use a Utah law to redeem real estate sold under a tax lien, but th… Read More
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Categories: IRS Debt Collection, Tax Tips for Professionals
Bankruptcy Court Lifts St…

Bankruptcy Court Lifts Stay for IRS to Collect Tax Lien on Retiree’s Pension

April 10th, 2020
Posted By
Joseph R. Viola
Bankruptcy attorneys often advise clients that filing their bankruptcy petition will put an end to collections efforts by creditors. However, tax attorneys know that the IRS does not give up so easily. A recent bankruptcy court case shows that an aut… Read More
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Categories: IRS Debt Collection, Tax Tips for Professionals

Practice Areas

IRS Audits & Examinations
IRS Liens, Levies & Seizures
IRS Installment Agreements & Offers in Compromise
Restoring Non-Filers to IRS Compliance
Relief from Joint & Several Liability (“Innocent” Spouse Relief)
Trust Fund Recovery Penalty
Abatement of Civil Penalties
IRS Administrative Appeals
U.S. Tax Court Petitions
Refund Litigation Against IRS in Federal Courts
Private Letter Rulings
IRS Audit Reconsideration
FBAR, FATCA and Offshore Voluntary Disclosure Initiatives

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