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Full-Text Articles in Law
Demystifying Irs Transcripts, Robert D. Probasco, Nikki Mccain, Ann Garza
Demystifying Irs Transcripts, Robert D. Probasco, Nikki Mccain, Ann Garza
Robert Probasco
No abstract provided.
Behind The Curtain - What Happens After You File A Federal Tax Return, Robert D. Probasco
Behind The Curtain - What Happens After You File A Federal Tax Return, Robert D. Probasco
Robert Probasco
No abstract provided.
Tax Shelter Disclosure And Penalties: New Requirements, New Exposures, Mary A. Mcnulty, Robert D. Probasco
Tax Shelter Disclosure And Penalties: New Requirements, New Exposures, Mary A. Mcnulty, Robert D. Probasco
Robert Probasco
One of the primary weapons in the battle against tax shelters has been mandatory disclosure to the IRS. The American Jobs Creation Act of 2004 built on this approach by clarifying and making consistent the various disclosure requirements and strengthening penalties for non-disclosure. To uncover abusive transactions, Congress drew the boundaries of disclosure so broadly that even legitimate tax planning transactions are covered. To understand the dangers in the new rules, one must look at the broad range of transactions covered, the participants covered, and the harsh penalties for nondisclosure.
- Transactions Covered. The disclosure requirements apply to six categories …
Tefra-Partnership Refunds: Five Steps To Protect A Partner’S Rights, Mary A. Mcnulty, Robert D. Probasco, Carla C. Crapster
Tefra-Partnership Refunds: Five Steps To Protect A Partner’S Rights, Mary A. Mcnulty, Robert D. Probasco, Carla C. Crapster
Robert Probasco
The Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) established a unified procedure for determining the tax treatment of partnership items at the partnership level rather than the partner level. The TEFRA-partnership refund procedures differ from the refund claim procedures that apply to other taxpayers. For a TEFRA partnership, a refund claim is an administrative adjustment request (AAF) and a notice of deficiency is a notice of final partnership administrative adjustment (FPAA). Procedures for the assessment of additional tax attributable to partnership items have received much attention in recent years, but the procedures concerning refunds are complex and full …
Advocating For Clients Whose Debts Were Assigned By The Irs To A Private Collection Agency, Michael Baillif, Robert D. Probasco, Miranda Rhyne
Advocating For Clients Whose Debts Were Assigned By The Irs To A Private Collection Agency, Michael Baillif, Robert D. Probasco, Miranda Rhyne
Robert Probasco
No abstract provided.
Advocating For Your Client In Trade And Business Expense Cases - Hobby Losses, Rosty Shiller, Robert D. Probasco, Miranda Rhyne
Advocating For Your Client In Trade And Business Expense Cases - Hobby Losses, Rosty Shiller, Robert D. Probasco, Miranda Rhyne
Robert Probasco
No abstract provided.
Partnership Audits And Litigation (Tefra), Robert D. Probasco, Jason Freeman
Partnership Audits And Litigation (Tefra), Robert D. Probasco, Jason Freeman
Robert Probasco
No abstract provided.
Don't Leave Money On The Table! Irs [Mis]Computation Of Interest, Robert D. Probasco
Don't Leave Money On The Table! Irs [Mis]Computation Of Interest, Robert D. Probasco
Robert Probasco
No abstract provided.
Ethics And Expected Changes To Circular 230, Fred Murray, Richard Goldstein, Matthew Lucey, Jack Manhire, Robert D. Probasco
Ethics And Expected Changes To Circular 230, Fred Murray, Richard Goldstein, Matthew Lucey, Jack Manhire, Robert D. Probasco
Robert Probasco
No abstract provided.
Transferee Liability, Robert D. Probasco
Circular 230 And Rules Of Professional Conduct In Giving Tax Advice, Robert D. Probasco
Circular 230 And Rules Of Professional Conduct In Giving Tax Advice, Robert D. Probasco
Robert Probasco
No abstract provided.
Transferee Liability, George Hani, Tamara Ashford, Robert D. Probasco
Transferee Liability, George Hani, Tamara Ashford, Robert D. Probasco
Robert Probasco
No abstract provided.
The New Application Of Transferee Liability, Robert D. Probasco
The New Application Of Transferee Liability, Robert D. Probasco
Robert Probasco
No abstract provided.
Tefra Audits And Refund Claims, Robert D. Probasco
Tefra Audits And Refund Claims, Robert D. Probasco
Robert Probasco
No abstract provided.
Federal Tax Update, Robert D. Probasco
Living With Transparency, Robert D. Probasco
Retention Requirements For Tax Records, Robert D. Probasco
Retention Requirements For Tax Records, Robert D. Probasco
Robert Probasco
No abstract provided.
Ethics And Standards Of Tax Practice In The New Age Of Transparency: From Self-Assessment To Self-Audit, Emily A. Parker, Robert D. Probasco
Ethics And Standards Of Tax Practice In The New Age Of Transparency: From Self-Assessment To Self-Audit, Emily A. Parker, Robert D. Probasco
Robert Probasco
No abstract provided.
Irs Audits And Appeals, Emily A. Parker, Robert D. Probasco
Irs Audits And Appeals, Emily A. Parker, Robert D. Probasco
Robert Probasco
No abstract provided.
Irs Audits And Appeals, Robert D. Probasco
Taxation Of Attorney Fees - Recent Developments, Robert D. Probasco, Marc Grossberg
Taxation Of Attorney Fees - Recent Developments, Robert D. Probasco, Marc Grossberg
Robert Probasco
No abstract provided.