Elisabeth O. Madden Esq. 4 posts 0 comments

Intrafamilial arrangements labeled as loans have long invited special scrutiny from the IRS. In some cases, the Service has successfully established that the arrangement was not a loan but another type of transfer, such as a gift.

This article considers newly issued proposed regulations under section 6694 of the Internal Revenue Code, which imposes tax return preparer penalties. The article discusses new rules and differences from existing authority concerning such…

This article explores the gift tax consequences of an exchange of promissory notes between family members when interest rates have dropped from when the original or old note was issue to the present time when the new note is issued.

Circular 230 sets forth ethical rules that lawyers and CPAs who practice before the IRS must follow. Violations of Circular 230 may result in severe disciplinary action, including disbarment from practice before the IRS and monetary…