A California residency audit is one of the most factually invasive and financially consequential examinations a taxpayer can face. The Franchise Tax Board (FTB) has become aggressive in auditing high-income residents who claim they moved — to Texas, Nevada, Florida, Washington, Tennessee, Wyoming, or anywhere else without a state income tax — and it has…
Continue reading ›If you received an IRS crypto letter 6173, Letter 6174, or Letter 6174-A, the IRS believes you may have engaged in one or more cryptocurrency transactions that were not properly reported. These letters are not random. They are the product of targeted enforcement built on data the IRS obtained through John Doe summonses against Coinbase,…
Continue reading ›The recent federal decision in Kwong v. United States may give millions of taxpayers a path to recover IRS penalties and interest assessed during the COVID-19 pandemic. If you, your business, or your trust paid Failure-to-File, Failure-to-Pay, or related interest on a tax obligation due between January 20, 2020 and July 10, 2023, the Kwong…
Continue reading ›Most taxpayers who receive an IRS audit notice make the same first call: their CPA. A few call a tax attorney. Almost none think to ask a more useful question — does the firm I’m hiring have anyone on the team who has actually sat on the other side of the audit table? A former…
Continue reading ›The IRS statute of limitations on tax debt — known inside the agency as the Collection Statute Expiration Date, or CSED — is one of the most misunderstood rules in federal tax collection. In theory, the IRS has ten years from the date of assessment to collect a tax liability. In practice, that clock is…
Continue reading ›By Alex Kugelman, Founder and Managing Attorney, Kugelman Law Not all cryptocurrency audits are the same. Understanding the types of cryptocurrency tax audits the IRS conducts — and what typically triggers each — gives crypto investors, traders, miners, and businesses a meaningful head start in evaluating their exposure and their options. A correspondence audit and…
Continue reading ›By Alex Kugelman, Founder and Managing Attorney, Kugelman Law Understanding the stages of an IRS crypto audit is the single most useful thing a taxpayer under examination can do. Each stage has its own rules, its own deadlines, and its own strategic opportunities. Missing a deadline or misjudging a stage can cost you settlement leverage,…
Continue reading ›By Alex Kugelman, Founder and Managing Attorney, Kugelman Law If you have received an IRS IDR in a crypto audit, the decisions you make in the next 15 to 30 days will materially shape the outcome of your examination. An Information Document Request is not a casual inquiry. It is the formal mechanism the Internal…
Continue reading ›Marin County is home to some of California’s highest earners, most successful entrepreneurs, and most sophisticated investors. It’s also a frequent target for IRS and California Franchise Tax Board (FTB) audit activity. If you’ve received an audit notice at your home in Mill Valley, Tiburon, San Rafael, Sausalito, or anywhere else across Marin, you need…
Continue reading ›If you’ve received an audit notice from the IRS or the California Franchise Tax Board (FTB), you’re probably feeling a mix of anxiety, confusion, and maybe even dread. You’re not alone. Every year, thousands of San Francisco residents and business owners open their mailboxes to find that dreaded letter — and most have no idea…
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