If you have received an IRS audit notice — or you are worried one might be coming — one of the first questions worth answering is who, exactly, will be examining your return. The answer matters more than most taxpayers realize. The IRS is not a single, undifferentiated organization. Examinations are conducted by specific employees…
Continue reading ›The Form 3520 penalty is one of the harshest in the Internal Revenue Code. A U.S. person who receives a gift or inheritance from a foreign person exceeding the annual reporting thresholds and fails to timely file Form 3520 faces a penalty of up to 25% of the gift or inheritance — even though the…
Continue reading ›An IRS CP2000 notice response is one of the most time-sensitive tasks a taxpayer will ever face. The CP2000 — often called an “underreporter notice” — arrives when the IRS believes the income, payments, credits, or deductions you reported on your tax return do not match what third parties reported about you. You have a…
Continue reading ›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 ›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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