Sean McMahon to Speak on IRS Collections Panel at Tax Controversy Conference

D. Sean McMahon Boston Tax Attorney
Tax attorney D. Sean McMahon is speaking on the “Collection: New IRS Techniques and Key Taxpayer Strategies” panel December 7, 2017 at the the 2017 ABA 34th Annual National Institute on Criminal Tax Fraud and 7th Annual National Institute on Tax Controversy. The tax conference is an annual meeting of American Bar Association’s criminal tax defense bar. The program brings together high-level government representatives, judges, corporate counsel, and private practitioners engaged in all aspects...
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Court Authorizes IRS to Seek the Identities of U.S. Taxpayers Who Have Used Virtual Currency

Boston Tax Attorney Blog Money
A federal court has granted the Internal Revenue Service (IRS) authority to serve a John Doe summons on Coinbase Inc., seeking information about U.S. taxpayers who conducted transactions in a convertible virtual currency during the years 2013 to 2015. IRS Definition of a John Doe Summons In the typical scenario, the IRS issue a summons to a third party to obtain information regarding a specific taxpayer whose identity is known. In contrast, a John Doe summons allows the IRS to obtain informati...
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Justice Department Reaches Final Resolutions Under Swiss Bank Program

Tax investigation
In a press release, the Department of Justice announced that “it has reached final resolutions with banks that have met the requirements of the Swiss Bank Program.  The Program provided a path for Swiss banks to resolve potential criminal liabilities in the United States, and to cooperate in the Department’s ongoing investigations of the use of foreign bank accounts to commit tax evasion.  The Program also provided a path for those Swiss banks that were not engaged in wrongful acts but nonethele...
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33rd Annual National Institute on Criminal Tax Fraud and the Sixth Annual National Institute on Tax Controversy

Bill Lovett and Sean McMahon will be attending the 33rd Annual National Institute on Criminal Tax Fraud and the Sixth Annual National Institute on Tax Controversy. We hope to see you there! Date: December 7-9, 2016 Location: Las Vegas, NV Register Here This program brings together high-level government representatives, judges, corporate counsel, and private practitioners engaged in all aspects of tax controversy, tax litigation, and criminal tax defense. Curriculum topics include:...
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Complex Business Tax Disputes – McMahon & Associates PC

Complex Business Tax Disputes - McMahon & Associates
Businesses must contend with a multitude of tax issues, any of which can create large problems for the business and its owners. The complexities of business accounting and the tax code often produce complex business tax disputes without a clear answer. One of the most surprising issues we frequently see affecting small and medium sized businesses is personal liability of the managing individuals for unpaid payroll taxes. Although operating a business through an entity is supposed to protect t...
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30,000 Taxpayers Who Submitted Voluntary Disclosures May Be Subject to Criminal Prosecution

Tax Evasion Boston Tax Attorney
Streamlined Offshore Voluntary Disclosure At Risk 30,000 US taxpayers have submitted streamlined offshore voluntary disclosures since 2012. Now the IRS and Justice Department are “taking all of that data and scrubbing it for leads,” Nanette Davis, a trial attorney in the Justice Department’s tax division, said at the New York University Tax Controversy Forum. As part of the U.S. Government’s efforts to collect unpaid taxes from U.S. taxpayers with undisclosed foreign bank accounts, the IRS o...
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Introducing McMahon & Associates IRS Tax Attorneys – Video Series

McMahon & Associates IRS Tax Attorneys
  When you need heart surgery, you want a heart surgeon, not your primary care physician. When the IRS comes knocking at your door, you want experienced tax counsel. McMahon & Associates exclusively handles IRS tax disputes. It the IRS is coming after you for an audit, an undeclared foreign bank account or trying to seize your property, you need a tax specialist who knows the IRS inside and out. Visit McMahon & Associates for more information. Watch more videos: ...
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Ten Most Litigated Tax Issues

Boston Tax Attorney Top Litigation
Every year the National Taxpayer Advocate analyzes tax cases litigated in federal court to identify the most commonly litigated issues. The ten most litigated tax issues from June 1, 2014 – May 31, 2015 are: Accuracy-Related Penalty Under IRC § 6662(b)(1) and (2) The IRS is authorized to impose a penalty if a taxpayer’s underpayment was the result of negligence or disregard for the the rules and regulations or an underpayment is deemed a “substantial understatement”. Trade or Busin...
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When the Money Isn’t Here: The Government’s Tools to Collect Outside the United States

Bill Lovett is presenting at the annual Criminal Tax Fraud and Tax Controversy National Institute, taking place December 9-11, 2015, at the Wynn / Encore Hotel in Las Vegas, NV. Tax Seminar: When the Money Isn’t Here: The Government’s Tools to Collect Outside the United States Panelists: Lindsay Clayton, William J. Lovett, Bruce Zagaris Moderator: Brian McManus Date: Friday, December 11, 2015 About the Program: Secrecy wasn’t the only reason that the money went offshore, and some ...
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Criminal Tax Investigations: An Overview for Accountants

The first thing for C.P.A.s, accountants, enrolled agents and tax preparers need to understand when one of their clients is under criminal investigation for tax fraud is THERE IS NO PRIVILEGE! Accountants should not discuss the criminal case with their client. Conversations between accountants and clients are not privileged and you could be compelled to disclose the substance of these conversations at a later date. Now that we are clear on not talking to your client about the criminal inves...
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