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Recent Articles & Treatises
- Registration now open for September 17, 2019 CPE Seminar, “IRC Sec. 199A: Wasn’t the Code to be Simplified?” August 26, 2019
- A Journey Through IRC Section 199A: Wasn’t the Code to be Simplified? July 25, 2019
- Tax News & Comment — August 2019 July 25, 2019
- Tax News & Comment – April 2017 March 13, 2017
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- FROM WASHINGTON & ALBANY — Current Election Probabilities; Tax Plans of Trump and Clinton May 13, 2016
- FROM FEDERAL AND NYS COURTS: Recent Developments & 2015 Decisions of Note May 13, 2016
- IRS & NYS DTF MATTERS: Recent Developments & 2015 Regs. & Rulings of Note May 13, 2016
- Creating and Maintaining Flexibility in Wills and Trusts May 13, 2016
- Escaping the Quandary Posed by Unreported Foreign Accounts May 13, 2016
- Like Kind Exchanges Alive and Well: An Update May 13, 2016
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- The Decedent's Final Income Tax Return
- Defeating The Right of Election in EPTL § 5-1.1-A
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Category Archives: IRS Audits
IRS Audit Procedures
PDF format: IRS Audit Procedures.wpd The process used to select returns for audit is not a random one. The oft-repeated phrase “audit lottery” is in many ways misleading since certain items, such as claiming a loss on the sale of … Continue reading
Posted in IRS, IRS Audits
Tagged 90 day letter, Appeals Office, audit, claim for refund, deficiency, IRS Audit, notice of deficiency, statute of limitations
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Taxpayer Rights During an IRS Audit
Pursuant to the “Taxpayer Bill of Rights,” enacted by Congress as part of the Internal Revenue Code, the IRS is required to disclose to taxpayers their rights, and the obligations of the IRS during the audit, appeals, refund, and collection … Continue reading
Posted in IRS, IRS Audits, Taxpayer Rights During Audit
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Administrative Appeals Within the Internal Revenue Service
At the heart of the Internal Revenue Service procedural engine lies the internal appeal process, whose function is to resolve taxpayer disputes through the use of negotiation and settlement, without the necessity of litigation. The Appeals office has “exclusive and … Continue reading
Taxpayer Bill of Rights 2 (May 1996)
New legislation governing the relationship between the IRS and the taxpayer has been approved by the House Ways and Means Committee. Given its wide congressional support, enactment seems likely, perhaps by as early as by next fall. The Taxpayer Bill … Continue reading
Posted in IRS, IRS Audits, Taxpayer Rights During Audit
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Law Offices of David L. Silverman 
Avoiding Boot Gain in Like Kind Exchanges
I. Introduction Circular 230 disclosure: Any tax advice herein is not intended or written to be used, and cannot be used by any taxpayer, for the purpose of avoiding any penalties that may be imposed under the Internal Revenue Code. … Continue reading →