by Daniel Pilla | Oct 20, 2023 | PTT Featured Article
TAX COURT REMANDS CDP CASE TO DEVELOP A RECORD Judicial Review Impossible Without an Adequate Record The recent Tax Court case of Bickel v. Commissioner, Docket No. 22038-22L, provides great insight into the manner in which the IRS is to conduct Collection Due Process...
by Daniel Pilla | Aug 1, 2023 | PTT Featured Article
COURT ORDERS ENFORCEMENT OF SUMMONS FOR CRYPTO DATA Digital Currency Trading Information is NOT Private In case you continue to believe that your digital currency trades are private, consider this. A United States District Court in California, on June 30, 2023,...
by Daniel Pilla | May 31, 2023 | PTT Featured Article
HOW TO DEDUCT EXPENSES INCURRED IN TRADING SECURITIES The Keys to Unlocking the Mysteriousand Elusive “Trader” Status With the advent of the Internet and the unfettered access we now have to national and international financial markets, it’s never been easier to trade...
by Daniel Pilla | Mar 31, 2023 | PTT Featured Article
ERC PROGRAM UNDER ATTACKProgram Named to IRS’s “Dirty Dozen” List In the February 2023 issue of PTT, I presented an article on the audit risks associated with the Employee Retention Credit (ERC). I pointed out that the IRS believes this credit is a source of...
by Daniel Pilla | Feb 8, 2023 | PTT Featured Article
HOW NOT TO RECONSTRUCT RECORDS Don’t Follow This Formula for Failure Lost or missing tax records are a regular and widespread problem. People lose records for a myriad of reasons, including fire, flood, hurricane, etc. My current client had her storage shed broken...
