Tax Law Issues

Tax form This page is the starting point for our collection of state and federal taxation materials.

IRS – Audit Letter Response

The most common mistake by a taxpayer facing an unexpected tax audit is to fail to contact a tax professional to at the very least sort out the preliminary issues the taxpayer will encounter.   Upon receipt MORE

IRS – Audit Reconsideration

Audit Reconsideration can be a viable action to eliminate an IRS tax liability that has been unfairly assessed without full consideration of the facts. MORE

IRS – Exemptions from Collection

Normally, the IRS issues a lien after taxes are unpaid. The lien attaches to all real and personal property of the debtor except that which is exempt by statute. MORE

IRS – Innocent Spouse Relief

Spouses filing jointly may unknowingly become liable for their spouse’s tax liability.  Nonetheless, even if a spouse knew of the tax underpayment, inequitable situations potentially allow for relief from tax debt.  MORE

IRS – Managing Tax Liability

A quick acting taxpayer can save hundreds and thousands of dollars in interest and penalties by proactively pursuing a resolution. MORE

IRS – Negligence Penalty Versus Gross Undervaluation Penalty

Under § 6662(h) a 40 percent penalty may be assessed for gross valuation misstatements. MORE

IRS – Quality Tax Opinion Letter eliminates penalties

To avoid penalties a tax opinion letter must comply with Circular 230. In recent years, the IRS has cracked down on the protections of a tax opinion letter. MORE

IRS – Tax-Free Corporate Reorganizations

Three types of statutory tax free reorganizations MORE

Labor and Industry – Washington

A major cost for Washington employers is the hourly charge imposed by Washington State’s Department of Labor and Industry (Workers’ Compensation). For manufacturing and construction businesses, the rates exceed $1 per hour. The calculation of L & I is a complex process requiring expertise. Often Washington employers make errors on their L & I forms – MORE

Unemployment Insurance – Oregon

 Franchisors may be imputed employer of franchisees employees Employment Dep’t v. Nat’l Maint. Contrs. of Or., Inc., 226 Ore. App. 473, 204 P.3d 151, (Or. Ct. App. 2009) (March 19, 2009)

Unemployment Insurance – Washington

Voluntary reduction in force loophole  Verizon Nw., Inc. v. Employment Sec. Dep’t, 164 Wn.2d 909, 194 P.3d 255, 2008 Wash. LEXIS 1040, 28 I.E.R. Cas. (BNA) 516, Unemployment Ins. Rep. (CCH) P9044 (Wash. 2008)

Business and Occupation (“B&O“) Tax – Washington

Washington State has a gross revenue tax in place of an income tax. MORE

Liability for Opinions – Omnicare

Putting Omnicare v Laborers District Counsel in Historical Perspective Omnicare, Inc., et al. v. Laborers District Council Construction Industry Pension Fund et al. Argued November 3, 2014—Decided March 24, 2015 Copy of Decision: 1503-Omnicare Overview The author is a...

Fraud on the Market

Although the Oregon securities law statute does not on its face require proof of scienter (intent to manipulate, deceive or defraud), the Oregon Court of Appeals read the requirement into the statute if the theory for relief is fraud on the market. Copy of the...

Failure to Reconvey: Quiet Title Without a Quiet Title Action

What do you do when a seller fails to reconvey the title to property following payment of the loan, then dies? Failure to reconvey puts a cloud on the title that must be quieted. Quiet title actions can be drawn out and expensive. Is there a way to obtain a quiet title without the quiet title action? This article explores four possible tools for obtaining a quiet title outside a traditional quiet title action.

Why Organize Early?

Although many company founders are reluctant to take the plunge into creating a corporate entity, often putting this step off for as long as possible, there are some good reasons to consider forming as soon as possible. Holding Period Stock Value The IRS will look at...