Top 5 Tax Controversy CPA Profiles

J. Frank Best a Tax Controversy CPA serving North and South Carolina with locations in Raleigh & Wilmington, NC  and North Myrtle Beach & Myrtle Beach, SC is rated in the Top 5 Tax Controversy CPA Profiles/Linkedin and as a United States Tax Court Litigator licensed in all States works to stay current on all IRS decisions concerning tax litigation to ensure we are fully informed and prepared for our clients.

J. Frank Best, Certified Public Accountant                                                            Admitted to Practice before the United States Tax Court

Telephone: 800.230.7090 | Email: bestcpa@bestirscpa.com                              

Practice Areas

  • TAX LITIGATION
  • TAX AUDITS
  • APPEALS & HEARINGS
  • IRS COLLECTION- ALL CIVIL ACTIONS
  • NON-FILERS AND DELINQUENT
  • DIVORCE & IRS PROBLEMS
  • INNOCENT SPOUSE
  • WORKER CLASSIFICATIONS
  • IRS ABUSE OF DISCRETION
  • CIVIL TAX FRAUD

IRS controversies are truly complicated. There is no magic to a resolution. Experience and qualifications dictate. Many advertisements and promises are intentionally false and misleading. By all means, avoid meeting with and having telephone contact with marketing/salespersons that will not be representing you. These people are highly trained to take your money. Choosing a local representative just makes good business sense.

 

Copyright © 2019, J. Frank Best, Certified Public Accountant

Top 5 Tax Controversy CPA Profiles

J. Frank Best a Tax Controversy CPA serving North and South Carolina with locations in Raleigh & Wilmington, NC  and North Myrtle Beach & Myrtle Beach, SC is rated in the Top 5 Tax Controversy CPA Profiles/Linkedin and as a United States Tax Court Litigator licensed in all States works to stay current on all IRS decisions concerning tax litigation to ensure we are fully informed and prepared for our clients.

J. Frank Best, Certified Public Accountant
Admitted to Practice before the
United States Tax Court

Telephone: 800.230.7090 | Email: bestcpa@bestirscpa.com
Copyright © 2019, J.Frank Best, Certified Public Accountant

Practice Areas

  • U.S. TAX COURT LITIGATION
  • TAX AUDITS
  • APPEALS & HEARINGS
  • IRS COLLECTION
  • LIEN OR LEVY ACTIONS
  • NON-FILERS AND DELINQUENT
  • PENALTY ABATEMENT
  • DIVORCE & IRS
  • INNOCENT SPOUSE
  • EMPLOYMENT CLASSIFICATIONS
  • IRS ABUSE OF DISCRETION
  • CIVIL FRAUD
  • CRIMINAL FRAUD-KOVEL

IRS controversies are truly complicated. There is no magic to a resolution. Experience and qualifications dictate. Many advertisements and promises are intentionally false and misleading. By all means, avoid meeting with and having telephone contact with marketing/salespersons that will not be representing you. These people are highly trained to take your money. Choosing a local representative just makes good business sense.

 

Top 5 Tax Controversy CPA Profiles

J. Frank Best a Tax Controversy CPA serving North and South Carolina with locations in Raleigh & Wilmington, NC  and North Myrtle Beach & Myrtle Beach, SC is rated in the Top 5 Tax Controversy CPA Profiles/Linkedin and as a United States Tax Court Litigator licensed in all States works to stay current on all IRS decisions concerning tax litigation to ensure we are fully informed and prepared for our clients.

J. Frank Best, Certified Public Accountant
Admitted to Practice before the
United States Tax Court

Practice Areas

  • U.S. TAX COURT LITIGATION
  • TAX AUDITS
  • APPEALS & HEARINGS
  • IRS COLLECTION
  • LIEN OR LEVY ACTIONS
  • NON-FILERS AND DELINQUENT
  • PENALTY ABATEMENT
  • DIVORCE & IRS
  • INNOCENT SPOUSE
  • EMPLOYMENT CLASSIFICATIONS
  • IRS ABUSE OF DISCRETION
  • CIVIL FRAUD
  • CRIMINAL FRAUD-KOVEL

IRS controversies are truly complicated. There is no magic to a resolution. Experience and qualifications dictate. Many advertisements and promises are intentionally false and misleading. By all means, avoid meeting with and having telephone contact with marketing/salespersons that will not be representing you. These people are highly trained to take your money. Choosing a local representative just makes good business sense.

Telephone: 800.230.7090 | Email: bestcpa@bestirscpa.com
Copyright © 2019, J.Frank Best, Certified Public Accountant

Top 5 Tax Controversy CPA Profiles

J. Frank Best a Tax Controversy CPA with locations in Raleigh & Wilmington, NC  and North Myrtle Beach & Myrtle Beach, SC is rated in the Top 5 Tax Controversy CPA Profiles/Linkedin and as a United States Tax Court Litigator licensed in all States works to stay current on all IRS decisions concerning tax litigation to ensure we are fully informed and prepared for our clients.

J. Frank Best, Certified Public Accountant
Admitted to Practice before the
United States Tax Court

Practice Areas

TAX LITIGATION
TAX AUDITS
APPEALS & HEARINGS
COLLECTION
PENALTY ABATEMENT
NON-FILERS & DELINQUENT
CIVIL FRAUD
CRIMINAL FRAUD – KOVEL
IRS ABUSE OF DISCRETION
DIVORCE AND IRS

IRS controversies are truly complicated. There is no magic to a resolution. Experience and qualifications dictate. Many advertisements and promises are intentionally false and misleading. By all means, avoid meeting with and having telephone contact with marketing/salespersons that will not be representing you. These people are highly trained to take your money. Choosing a local representative just makes good business sense.

Telephone: 800.230.7090 | Email: bestcpa@bestirscpa.com
Copyright © 2019, J.Frank Best, Certified Public Accountant

Offer in Compromise

A recent Tax Court decision was reported dealing with Offer in Compromise. J. Frank Best, Tax Controversy CPA/U. S. Tax Court Litigator with locations in Raleigh and Wilmington, NC  & North Myrtle Beach and Myrtle Beach, SC works to stay current on all IRS decisions concerning tax litigation to ensure we are fully informed and prepared for clients.

Procedure

IRS’s Rejection of Offer in Compromise of 4 Percent of Tax Liability Was Not an Abuse of Discretion: In Snipes v. Comm’r, T.C. Memo. 2018-184, the Tax Court held that, in view of actor Wesley Snipes failure to provide bona fide documentation to prove his assets and financial condition, as well as the disparity in an offer in compromise (OIC) he made to the IRS versus his reasonable collection potential as determined by IRS, an IRS settlement officer did not abuse her discretion by rejecting the actor’s OIC, refusing to conduct an expedited transferee investigation, or sustaining the filing of a notice of federal tax lien. The actor had made a cash OIC of $842,000, which was less than 4 percent of his total underlying liability.

Settlement Proceeds Taxable: Tax Controversy CPA/U. S. Tax Court Litigator

A recent Tax Court decision was reported dealing with Settlement Proceeds.  J. Frank Best, Tax Controversy CPA/U. S. Tax Court Litigator with locations in Raleigh and Wilmington, NC  & North Myrtle Beach and Myrtle Beach, SC works to stay current on all IRS decisions concerning tax litigation to ensure we are fully informed and prepared for clients.

Discrimination and Hostile Work Environment Settlement Is Taxable: In Zinger v. Comm’r, T.C. Summary 2018-33, the Tax Court held that the $20,000 from Settlement Proceeds received by the taxpayer was not excludable from income under Code Sec. 104(a)(2). The court concluded that the settlement payment was for the resolution and withdrawal of the taxpayer’s discrimination and hostile work environment claims and not on account of personal physical injuries or physical sickness.

IRS Disallows Dependents. Can We Assist You? Raleigh, Wilmington-N. Myrtle Beach, Myrtle Beach

A recent Tax Court decision was reported dealing with Dependents.  J. Frank Best, Tax Controversy CPA/U. S. Tax Court Litigator with locations in Raleigh and Wilmington, NC  & North Myrtle Beach and Myrtle Beach, SC works to stay current on all IRS decisions concerning tax litigation to ensure we are fully informed and prepared for our clients.

Parents Who Lost Custody of Children Could Not Claim Them as Dependents or Take Child Tax Credit or EITC

The Tax Court held that the biological parents of two dependent children who were adopted by, resided with and received primary financial support from their maternal aunt during the entire year at issue were not entitled to claim the children as dependents and, as a result, could not take the child tax credit or the earned income credit. The Tax Court reasoned that, although the children visited with their parents when not in school, the children did not share a principal place of abode with their parents, making the parents ineligible to claim the children as dependents or take the credits. Jusino v. Comm’r, T.C. Memo 2018-112.

United States Tax Court Decision of the Week-Underpayment Penalties

A recent Tax Court decision was reported dealing with Underpayment Penalties and additional tax.  J. Frank Best, Tax Controversy CPA/U. S. Tax Court Litigator with locations in Raleigh and Wilmington, NC  & North Myrtle Beach and Myrtle Beach, SC works to stay current on all IRS decisions concerning tax litigation to ensure we are fully informed and prepared for our clients.

Couple That Relied Entirely on Tax Prep Software Can’t Avoid Underpayment Penalties: In Ayissi-Etoh v. Comm’r, T.C. Memo. 2018-107, the Tax Court held that a couple was liable for additional taxes for (1) underreporting certain income and not substantiating certain deductions, and (2) underreporting self-employment income from the International Monetary Fund that was subject to self-employment tax. In addition, the court held that the couple was liable for penalties for substantially understating their tax liabilities because the couple did not seek advice from a qualified tax professional but relied entirely on tax preparation software and their tax deficiency amounts exceeded both $5,000 and 10 percent of the amounts required to be shown on their returns.

The issues for decision are whether petitioners: (1) underreported a taxable refund of State income tax; (2) are entitled to deductions claimed on Schedules C, Profit or Loss From Business; (3) are entitled to deductions claimed on Schedules A, Itemized Deductions, for charitable contributions and unreimbursed employee expenses; (4) are liable for self-employment tax on wages received from an international organization; and (5) are liable for accuracy-related penalties. We resolve all issues in respondent’s favor.

Restitution Payment- J. Frank Best, Tax Controversy CPA/U.S. Tax Court Litigator

Restitution Payments

A recent Tax Court decision was reported dealing with Restitution Payments as Part of a Criminal Sentence.  J.  Frank Best, Tax Controversy CPA/U. S. Tax Court Litigator in Raleigh and Wilmington, NC  & North Myrtle Beach and Myrtle Beach, SC works to stay current on all IRS decisions concerning tax litigation to ensure we are fully informed and prepared for our clients.

The Tax Court held that a taxpayer was not entitled to a miscellaneous itemized deduction for a $400,000 restitution payment made in 2014. The court concluded that (1) the taxpayer did not show that the restitution payment promoted or protected his trade or business of being an employee; (2) the taxpayer did not present any evidence that the primary purpose or motive for the payment was other than that he was required to make the payment as part of a criminal sentence; and (3) the taxpayer did not enter into the restitution transaction with the intention of making a profit. Washburn v. Comm’r, T.C. Memo. 2018-110.

Conclusion

The Tax Court held that Washburn could not deduct the restitution payments as a miscellaneous itemized deduction in 2014. The court began by noting that the restitution payments would be deductible as a miscellaneous itemized deduction if they constituted expenses attributable to the performance of services as an employee under Code Sec. 162(a), losses related to the performance of services as an employee under Code Sec. 165(c)(1), or losses incurred in a transaction entered into for profit under Code Sec. 165(c)(2).

“Serious IRS Problem Resolution”/J. Frank Best, Tax Controversy CPA/U. S. Tax Court Litigator

Serious IRS Problem Resolutions

J. Frank Best is rated in the Top 5 Tax Controversy CPA Profiles/Linkedin and is a United States Tax Court Litigator licensed in all States and works to stay current on all IRS decisions concerning tax litigation to ensure we are fully informed and prepared for our clients.

Telephone 800.230.7090   Email: bestcpa@bestirscpa.com  Web: bestirscpa.com