- Ann Klasing
-
Articles
- Federal Tax Evasion Investigations: Innocent Until Proven Otherwise
- Fighting an IRS Tax Audit: What You Need to Know
- Foreign Bank Account Disclosure Requirements and Tax Evasion Risks
- IRS Crackdown on Offshore Accounts Drawing International Criticism
- IRS Reopens Voluntary Disclosure Program for Taxable Offshore Assets
- IRS will soon be able to detect previously undisclosed foreign accounts
- Non-Filers: Act Quickly and Carefully to Minimize Risks
- Practicing Good Habits Before an Audit
- Tips for Avoiding an IRS Tax Audit
- Attorney
- Attorney Client Privilege Discussion
- Business Law
- Client Testimonials
- Contact
- Disclaimer
- Estate Planning
- Firm Overview
- Firm Overview | David Klasing
- Home
- Irvine, CA Office Location
- Los Angeles, CA Office Location
- Offer in Compromise Estimator
- Search
- Shaun McNaughton
- Staff
- Su Ralston
-
Tax Law
- Audit Representation
-
Audit Representation FAQ
- Are all audits the same or do they come in different flavors?
- Can I have the examination transferred to another area?
- Can I record the IRS interview with the IRS revenue agent and is it a good idea to do so?
- Do I have the right to know why I was selected for examination?
- Do I have to submit to being interview by the taxing authority directly?
- If the IRS discovers an error in a tax year under audit, will they look at other tax years? How many years worth of returns are at risk during an audit?
- I have been audited several times in the recent past. Is there anyway to stop the IRS from repeatedly auditing me?
- Is there anything I can do to decrease the odds of subsequent negative consequences stemming from an in-person interview with a taxing authority?
- What are the most common reasons the IRS decides to conduct an audit? What are they commonly looking for in an audit?
- What can I do to prepare for an audit?
- What is involved with appealing disagreements, both within the IRS and before the courts?
- What is the largest risk you expose yourself to if you choose to attend an audit without proper representation?
- What is the most common audit technique applied by the taxing authorities?
- What is the significance of receiving a 30 day and 90 day letter following an audit?
- What is the worst that can happen if I choose to represent myself in an audit?
- What options are available to me where I am unable to pay a deficiency, penalties and interest at the conclusion of an audit?
- What rights do I have during an audit?
- What rights do I have where I disagree with the auditor’s findings at the conclusion of an audit?
- What should I do if I suspect that the IRS may be considering criminally investigating me?
- What will happen if I do not respond to the taxing authorities audit notice?
- Why should I hire an attorney rather than any other type of tax professional to represent me in an audit before the IRS, Franchise Tax Board or State Board of Equalization?
- Why should I hire The Tax Law Office of David W. Klasing to represent me in an audit before the IRS, Franchise Tax Board or State Board of Equalization?
- Bookkeeping & Accounting
- Criminal Tax Representation
-
Criminal Tax Representation FAQ
- Are there any rules that govern what an IRS criminal investigation special agent can and cant do in investigating me?
- How can tax preparers, attorneys, or accountants be charged with aiding or assisting the crime of filing a false return? How can they be punished?
- How does the Criminal Investigation Division of the IRS generate leads concerning suspected tax crimes?
- How does the Criminal Investigation Division of the IRS select a tax crime lead for full investigation?
- How does the IRS go about criminally prosecuting suspected tax crimes?
- How does the IRS reward informant leads concerning suspected tax crimes?
- How will the government attempt to prove a deficiency in a tax evasion case?
- How will the government use my prior crimes or tax convictions in seeking a new criminal tax conviction?
- Is it a good strategy to request a criminal investigation conference before an IRS special agent's investigative report is finished?
- Is the IRS required to warn me when I am placed under criminal investigation?
- Is there a method by which I might avoid criminal prosecution where I committed a tax crime in the past? Should I possibly consider making a Voluntary Disclosure?
- Is there an increased possibility of civil action when the IRS is investigating me criminally?
- What are the usual defense tactics that make it hard for the government to prove willfulness?
- What can a tax attorney argue to attempt to stop the progression of a criminal case at the District Counsel review level of the IRS or at the Department of Justice level?
- What can you generally tell me about tax crimes?
- What considerations should be taken into account where I am faced with a continuing filing requirement when I suspect a criminal investigation is pending?
- What crimes as set forth in the Federal Criminal Code can apply to tax matters?
- What generally are the crimes of making, subscribing, and filing a false return or document? How are they punished?
- What is commonly contained in a CID special agent's report recommending criminal prosecution for a tax crime when finished?
- What is involved with the discovery process in a criminal tax case?
- What is the government required to include in an indictment or an information in a criminal tax case?
- What is usually the hardest element of a tax crime for the Federal Government to prove?
- What methods of gathering circumstantial evidence does the IRS Criminal Investigation Division commonly employ in proving a tax crime?
- What role does a Grand Jury play in the IRS attempting to prosecute a tax crime?
- What specifically are the crimes of failure to keep records or supply information and how are they punished?
- What specifically is a failure to make a return, supply information, or pay tax? How is it punished?
- What specifically is attempted evasion of payment of tax?
- What specifically is attempted income tax evasion?
- What specifically is income tax evasion and how is it punished?
- What specifically is the crime of failure to pay tax and how is it punished?
- What specifically is the crime of making or subscribing a false return or other document? How is this crime punished?
- What tactics does the Criminal Investigation Division commonly employ in conducting an investigation?
- What tax crimes surround trust fund taxes and employment tax forms?
- What types of defenses or mitigation techniques are available to an actual or potential criminal charge brought by the IRS?
- Defending Audits Challenging Taxpayers' Status as Real Estate Professionals
- Employment Tax Representation
- FBAR Compliance and Disclosure
-
FBAR Compliance and Disclosure FAQ
- Given that the expired FBAR Voluntary Disclosure program generally limited the requirement to amend previously filed returns to six years, how many years will I be required to amend if I make a Voluntary Disclosure?
- Given that the FBAR Voluntary Disclosure program containing limited civil penalties ended October 15, 2009 and the potential civil penalties delineated above, what is the maximum I am likely to pay if I make a voluntary disclosure related to my foreign account in order to limit my exposure to criminal prosecution?
- How likely am I to be criminally prosecuted where I missed the October 15, 2009 deadline and subsequently decide to make a Voluntary Disclosure?
- If I do not have the ability to full pay can I still participate in the IRS's Voluntary Disclosure Practice?
- The following is a summary of potential reporting requirements and civil penalties that could apply to a taxpayer, depending on his or her particular facts and circumstances.
- What are some of the criminal charges I might face if I do not come in under voluntary disclosure and the IRS finds me?
- What are the common characteristics of the FBAR voluntary disclosures that have been made to date?
- What are the required elements to make a valid Voluntary Disclosure given that the FBAR Voluntary Disclosure program ended October 15, 2009?
- What exactly is an FBAR? (Report of Foreign Bank and Financial Accounts)
- What if the taxpayer has already filed amended returns reporting the additional unreported income, without making a Voluntary Disclosure (i.e., quiet disclosure)?
- When determining the highest amount in each undisclosed foreign account for each year or the highest asset balance of all undisclosed foreign entities for each year, what exchange rate should be used?
- Why should you consider making a Voluntary Disclosure even though the FBAR Voluntary Disclosure program ended October 15, 2009?
- International Tax Law
-
International Tax Law FAQ
- How is Dividend Income Sourced?
- How is Nationality and Residency Determined for Federal Tax Purposes?
- What Are the Basic Rules for Sourcing Income and Why are These Rules Important?
- What Are the Basics of U.S. International Taxation?
- What are the Basic Sourcing Rules for Interest Income?
- What Creates Nexus Over Foreign Persons and Activities Sufficient to Make Them Subject to U.S. Tax?
- What Creates Nexus Over U.S. Persons or Resident Aliens Sufficient to Make Their Foreign Income Subject to U.S. Tax?
- What other Source Rules Focus on the Payee’s Residence?
- What Sourcing Rules Turn on an Asset’s Location?
- IRS Appeals Representation
-
IRS Appeals Representation FAQ
- Does the filing of an appeal stop interest and penalties from accruing while the appeal is pending?
- How does the appeals process ordinarily conclude?
- How do you request a CDP or equivalent hearing with the Office of Appeals?
- How is a Tax Appeal initiated?
- How long will it be before I hear from the Appeals office after I file my appeal request or protest?
- If I choose to litigate my tax controversy is it possible to recover my administrative and litigation costs?
- Is help available within the IRS itself if I am experiencing economic harm because of an IRS collection action?
- Is there any way that my decision to bypass Appeals and go straight to Tax Court could backfire?
- Should I consider an appeal where the IRS has rejected or terminated my installment agreement?
- What are the main advantages of filing an Appeal?
- What are the possible disadvantages of filing an Appeal rather than proceeding straight to Tax Court?
- What can I expect from Appeals?
- What commitments does the IRS Appeals Office expect from taxpayers?
- What commitments does the IRS Appeals Office make in dealing with taxpayers?
- What exactly is the function of the IRS Appeals Office?
- What happens if I do not respond to a Notice of Deficiency within the required 90 days?
- What is the first thing I should do If I do not agree with the results of an audit?
- What is the procedure to appeal a collection action instituted by the IRS?
- What must be included in protest of IRS Audit findings to be granted an Appeal and position myself for a favorable outcome?
- What protections are in place to make sure the Appeals Office is truly independent?
- What recourse do I have if I cannot reach an agreement with the IRS Office of Appeals?
- What types of collection actions can be appealed?
- When do I know for sure that I'm ready to request Appeals Conference?
- Why should I consider engaging the Tax Law Office of David W. Klasing to, at a minimum, prepare my Tax Court Petition or my Protest in order to be granted an Appeal?
- Why should I consider engaging The Tax Law Office of David W. Klasing to help negotiate my Appeal?
- Why would I not want my original tax preparer to represent me in my appeal (or in my audit)?
- You are the prevailing party if you meet all the following requirements:
- Non-Filer Assistance
-
Non-Filer Assistance FAQ
- Am I likely to be audited by the taxing authorities once I file the delinquent prior year returns?
- Can a deficiency on a substitute return be discharged in a subsequent bankruptcy?
- Can a deficiency on a substitute return be modified by a subsequent delinquent return?
- Do I have to file every delinquent tax return for every missing tax year?
- How does the IRS identify non-filers?
- How important am I to the Federal and State Governments as a non-filer?
- How likely is it that I will face criminal prosecution and go to jail when I file my delinquent tax returns?
- If I am due a refund or a credit on a delinquent tax year will I receive them?
- Once enforcement action has begun by the IRS, can I expect to hear from the state of California on the same issue (and visa versa)?
- Should I use an attorney, EA or a CPA to represent me when I re-enter the tax system?
- What are the common reasons people drop out of the tax system?
- What happens after a non-filer has been identified by the IRS?
- What happens where the IRS have not previously filed substitute returns?
- What if I have a trusted relationship with a tax preparer and wish to have the additional protection of having a tax attorney represent me when I re-enter the tax system?
- What is the government likely to do to force me to file the returns I have not filed?
- What penalties is the IRS able to impose on the delinquent tax filings?
- What should I do to re-enter the tax system?
- What specifically can the Tax Law Office of David W. Klasing do to help me re-enter the system?
- Will any subsequent collection action taken by the taxing authorities after filing my delinquent returns affect my personal or business credit rating?
-
Offer In Compromise FAQ
- How does the acceptance of an Offer in Compromise affect the collection statute of limitations?
- How does the filing of an Offer in Compromise or appealing a rejection affect ongoing IRS collection actions?
- How does the IRS notify me that my Offer in Compromise has been accepted?
- How exactly do I apply for an Offer in Compromise?
- How long does it take to get an Offer in Compromise?
- How will making an Offer in Compromise effect my current installment agreement?
- Is an accepted Offer in Compromise public record?
- On what grounds and in what circumstances will the IRS entertain an Offer in Compromise?
- What are the objectives of the IRS Offer in Compromise Program?
- What are the prerequisites to obtaining an Offer in Compromise?
- What are the three ways in which and Offers in Compromise can be paid?
- What can I do to protect my Offer in Compromise from being revoked once it has been approved?
- What exactly is an Offer in Compromise?
- What happens where the IRS finds something technically wrong with my Offer?
- What if my Offer in Compromise concerns tax liabilities that I incurred prior to getting married?
- What is important to know about my Form 433A collection information statement to be submitted with my Offer in Compromise?
- What legal effects does entering into an Offer in Compromise have on a taxpayer?
- What payments are required to be made with an Offer in Compromise?
- Why might my offer have been found to have been unacceptable?
- Why should I choose the Tax Law Office of David W. Klasing help me with my Offer in Compromise?
- Will making an Offer in Compromise affect any possible criminal tax liability exposure?
- Offers In Compromise
- Previous Voluntary Disclosure Program
- Tax Evasion & Fraud Representation
- Tax Litigation
-
Tax Litigation FAQ
- What are the basic requirements in order to litigate a Tax Court deficiency action in Federal Tax Court?
- What are the basic requirements in order to litigate a valid refund claim in either the Court of Federal Claims or a Federal District Court?
- What discovery methods apply in Federal Tax Litigation?
- What is a notice of deficiency?
- What tax issues can be successfully litigated?
- Which federal court should a I chose to litigate my tax issue in and why?
- Who can represent a taxpayer in the Tax Court?
- Who has the burden of proof in Tax Litigation?
- Tax Motivated Bankruptcy
- Tax Preparation & Compliance
- Tax Research
- Tax Transactions
- Will making an Offer in Compromise affect any possible criminal tax liability exposure?
