Questions? Please call:
952-855-8210
Questions? Please call:
952-855-8210

Welcome to the Regan Tax Law BLOG



Challenging an Assessment After the IRS or the Minnesota Department of Revenue (MDR) Completes an Audit of Your Return and Starts Collection Actions Against You.

Posted by Tom Regan | Sep 10, 2022 | 0 Comments

When it is too late to file a corrected tax return and you think the IRS or MDR assessment is wrong, you may still be able to challenge the assessment without going to court. For the IRS, the procedure is known as an Audit Reconsideration Request (AR). The IRS has the discretionary authority to a...

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Using the Collection Due Process (CDP) Hearing and the Collection Appeals Program (CAP) Procedures to Challenge the Internal Revenue Service’s (IRS) Decision to Pursue You for Unpaid Taxes.

Posted by Tom Regan | Sep 10, 2022 | 0 Comments

You have many options to challenge the IRS's efforts to collect tax, penalties, and interest. Two common procedures are the Collection Due Process (CDP) hearing and the Collections Appeal Program (CAP) hearing, depending on the circumstances.  The CDP program gives you the right to appeal the fi...

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Hold on Certain IRS Collection Activities

Posted by Tom Regan | Mar 28, 2020 | 0 Comments

The IRS is making efforts to take some pressure off taxpayers during the COVID 19 pandemic. By now, most taxpayers are aware that the filing of their 2019 Form 1040, and the payment of the tax relating to that Form, are not due until July 15, 2020. This was a good first step for the IRS. Since then, the IRS issued News Release IR-2020-59 notifying taxpayers with outstanding tax obligations of extensions for dealing with some of these obligations and explaining relief for those involved in installment agreements and negotiating an Offer in Compromise.

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How Long Do I Need To Keep My Tax Records?

Posted by Tom Regan | Mar 14, 2017 | 0 Comments

I am often asked how long do I have to maintain records to protect myself against actions by the Internal Revenue Service? Along with that question comes the question about whether the IRS has the burden of proving a taxpayer owes the tax (assuming it met its burden when first assessing the tax) ...

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Late Returns and Discharging Taxes in Bankruptcy

Posted by Tom Regan | Aug 21, 2016 | 0 Comments

If you want the chance to discharge your individual income taxes in bankruptcy, in Minnesota, file your returns. This is still an option if you live in the Eighth Circuit (this includes Minnesota). It is not an option in some other circuits. More courts are accepting or at least entertaining the...

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Employment Taxes and Early Intervention

Posted by Tom Regan | Jun 23, 2016 | 0 Comments

The IRS appears to be more serious about pursuing and prosecuting companies that do not pay their employment taxes. The IRS's first step to address this problem with unpaid employment taxes is to contact these companies as early as possible, hoping this early intervention will prevent the misuse ...

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IRS Summons – Defending Against the Summons

Posted by Tom Regan | Apr 30, 2014 | 0 Comments

The United States Supreme Court is considering an investor's objection to summonses issued by the IRS. United States v. Clarke, No. 13-301.  Mr. Clarke, the investor, is arguing the IRS improperly issued summonses as retribution against him and his business partners for resisting an audit and tha...

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I Owe the IRS Money – What Can I Do?

Posted by Tom Regan | Feb 09, 2014 | 0 Comments

We often receive telephone calls and e-mails from individuals and businesses who have been contacted by the IRS for a tax obligation owing and they don't know what to do. There are many options for dealing with these obligations. The correct option depends on the facts of the case. Unfortunately,...

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Claim for Refund of the Trust Fund Recovery Penalty

Posted by Tom Regan | Jan 06, 2014 | 0 Comments

An individual assessed the Trust Fund Recovery Penalty (TFRP) has the option to pay just a portion of the assessment to gain access to a court. This is different from the requirement for income taxes, which calls for payment, in full, of the tax, penalty, and interest, before a court can hear the case.

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Section 530 – Reasonable Basis

Posted by Tom Regan | Apr 12, 2013 | 0 Comments

 This is the fourth article in a series dedicated to using Section 530 of the Revenue Act of 1978 as protection for businesses that have been using independent contractors, in good faith, but are now facing an IRS or State of Minnesota audit of that practice. Section 530 may be 34 years old, but ...

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Section 530 – Substantive Consistency

Posted by Tom Regan | Mar 05, 2013 | 0 Comments

This is the third article in a series dedicated to using Section 530 of the Revenue Act of 1978 as protection for businesses that have been using independent contractors, in good faith, but are now facing an IRS or State of Minnesota audit of that practice. Section 530 may be 34 years old, but it...

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Section 530 – Reporting Consistency

Posted by Tom Regan | Feb 12, 2013 | 0 Comments

This is the second article in a series dedicated to using Section 530 of the Revenue Act of 1978 as protection for businesses that have been using independent contractors, in good faith, but are now facing an IRS or State of Minnesota audit of that practice. Section 530 may be 34 years old, but i...

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Real Estate Professional – Maintaining Adequate Records

Posted by Tom Regan | Dec 27, 2012 | 0 Comments

Doing well in a full time job is hard enough, but some people, for many reasons, spend significant time, energy, and money away from their “regular job” trying to build themselves a better future through real estate. They often feel like they spend every waking hour away from their regular job de...

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Can I discharge income taxes in bankruptcy?

Posted by Tom Regan | Oct 29, 2012 | 0 Comments

Yes, under the right circumstances. Income taxes (not trust-fund or withholding taxes) are dischargeable in a Chapter 7 Bankruptcy if certain conditions are met. Has it been more than three years since the original due date, including extensions, for the return? If not, the taxes are not dischar...

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