Does The National Football League Deserve Tax-Exempt Status?

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Now here is a fact that is not so widely known – the National Football Association which you figure makes a ton of money is recognized by the IRS as a tax-exempt entity.  You heard me right – the National Football League does not pay income taxes as any for-profit-company would.

Section 501(c)(6) of the Internal Revenue Code provides for the exemption from  tax entities which are not organized for profit and no part of the net earnings of which inures to the benefit of any private shareholder or individual.

Those entities are specifically:

  1. business leagues,
  2. chambers of commerce,
  3. real estate boards,
  4. boards of trade and
  5. professional football leagues.

It’s obviously notable that only professional football leagues are included here, as opposed to all sporting leagues.

It seems inconceivable that the NFL is not “engaging in a regular business of a kind ordinarily carried on for profit”.  How are their efforts to maximize profits any different than those of Major League Baseball, the National Basketball Association or the National Hockey League?

Well professional football leagues were not always included in this list.  This change dates back to 1966, when the tax code was amended to give a professional football league tax-exempt status in order to facilitate the merger of the NFL and the old American Football League.

So one may ask – if I go on NFL.com and order super bowl tickets, can I claim a charitable deduction? Well the tax law states that when you make a donation to a charity and receive a benefit back, the amount deductible is only the excess of your contribution over the benefit you receive. Also, your charitable deduction cannot include the value of any benefits you received from the charity.  An example would be where you paid $200 to attend a charitable ball for which the charity states that the value of the ticket is $75.  In such an instance your charitable deduction would be $125.

Description: The Law Offices Of Jeffrey B. Kahn, P.C. want to help you avoid increases in taxes in IRS audits over charitable giving. Learn some tips from a leading tax attorney in Los Angeles.

 

Taxpayer Scores $862,000 from IRS after Tripping over a Phone Cord

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A taxpayer who met with a Revenue Officer at an Internal Revenue Service office on Long Island successfully sued the IRS for $862,000 after he was injured by tripping over a phone cord.

William Berroyer claimed in his lawsuit that he could no longer play golf or have intimate relations with his wife more than once a month after he fell during a 2008 conference with a Revenue Officer at an IRS office in Hauppauge, NY, according to the New York Post. He had visited the IRS to work out a payment agreement for a $60,000 tax bill when he tripped on the phone cord and fell against a cabinet.
After leaving the IRS, he telephoned the IRS Revenue Officer from the parking lot to inform him that he had lost the sense of feeling in his leg and was suffering from shoulder pain. He then spent 17 days in hospitals and rehabilitation centers recovering from his injury.

In his lawsuit he claimed $10 million in damages.  Attorneys for the IRS claimed he was exaggerating his injury, but the judge ultimately awarded him $862,000 for pain and suffering. And the big prize is because this was for pain and suffering, he won’t have to pay taxes on the damages!

So now that the IRS has tucked away all their telephone cords, how can taxpayers who owe the IRS avoid collection action?

  1. Offer In Compromise. This is a formal application to the IRS requesting that it accept less than full payment for what you owe in taxes, interest, and penalties. An offer in compromise may allow you to settle back taxes or IRS liability at a substantial discount on the basis of doubt as to collectability, liability, or effective tax administration. In addition, while your offer is under consideration, the Internal Revenue Service is prohibited from instituting any levies of your assets and wages. Most people do not have the necessary skills or knowledge of the IRS collection process to make an offer in compromise that is in their best interest and can be processed by the IRS. Government figures show that 75% of offers are returned at the beginning due to forms being filled out incorrectly, and of the 25% that are processed, approximately 50% are rejected.
  1. Installment Agreement. Allows you to pay IRS debt in full in smaller, more manageable amounts, usually in equal monthly payments. The amount of your installment payment will be based on the amount you owe and your ability to pay that amount within the time available to the IRS to collect tax debt from you.  However, be aware that because you are financing your liability with IRS, interest and penalties will continue to accrue.  Most installment agreements are set up with level monthly payments but there are also different types and terms of installment agreements which if you qualify may be more suitable for you.  The variations are not publicly offered by IRS – only a seasoned tax attorney would know to ask for them.
  1. Uncollectible Status.  Occurs when the IRS has determined that they are presently unable to collect the taxes from the taxpayer by full payment, through an Installment Agreement or by way of an Offer in Compromise.  Once the account is placed on a Currently Uncollectible (“CNC”) status, the IRS does not pursue collection activity against the taxpayer and the statute of limitations on the tax liabilities will continue to run. Generally, unless the taxpayer’s financial situation changes, the account will remain on a CNC status until the tax liabilities expire. However, if the taxpayer’s financial situation improves the account will be taken off of CNC status so that the IRS can collect the taxes through full payment or an Installment Agreement. CNC although temporary could provide interim relief to taxpayers who all of a sudden run into financial hardship.

A consultation with the Law Offices Of Jeffrey B. Kahn, P.C. can help you determine what the best strategy is for you.

Description: The Law Offices Of Jeffrey B. Kahn, P.C. has helped many people avoid collection action by the IRS and State tax agencies. Working with a tax attorney in Los Angeles is the best bet for reducing or eliminating the amount you owe.

Foreign Trusts – Filing Requirements

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All U.S. taxpayers who have an interest in, or signatory or other authority over foreign trust accounts must file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR), if the aggregate value of the foreign trust accounts exceeds $10,000 at any time during the calendar year.  As of October 1, 2013 the FBAR form must be filed through the Financial Crimes Enforcement Network’s (FinCEN’s) Bank Secrecy Act E-Filing System on or before June 30th of the year following the calendar year being reported.  For example, to report foreign accounts held open in 2013, the taxpayer must file the FBAR by June 30, 2014.

A U.S. taxpayer is deemed to have a foreign interest in a foreign trust account in two situations.  First, the owner of record or holder of legal title is a trust of which the U.S. taxpayer is the trust grantor and has an ownership interest in the trust for U.S. federal tax purposes.  Second, the owner of record or holder of legal title is a trust in which the U.S. taxpayer has a greater than 50 percent present beneficiary interest in the trust’s assetsor in the trust’s current income for the calendar year.  The U.S. person who is a trust beneficiary may be exempted from filing an FBAR, however, if the trust, trustee, or agent of the trust is a U.S. person and files an FBAR disclosing the trust’s foreign financial accounts.  A U.S. person who is only a reminder beneficiary or is the beneficiary of a discretionary trust is not required to file an FBAR for the trust as these interests are not “present” beneficiary interests.

In addition to filing an FBAR form, the U.S. taxpayer with an interest in a foreign trust account must follow certain reporting requirements on his or her annual tax return.  First, the U.S. taxpayer must include a completed Schedule B, Interest and Ordinary Dividends, with his or her annual tax return.  On Schedule B, the taxpayer will complete Part III, Foreign Accounts and Trusts.  Questions 7a asks whether, at any time in the year, the taxpayer had a financial interest in or signatory authority over a foreign financial account.  Question 7b also asks whether the taxpayer is required to file an FBAR, and if so, in which foreign country the financial account was located.  Finally, Question 8 asks whether the U.S. taxpayerreceived a distribution from, or was the grantor of, or transferor to, a foreign trust.

If the U.S. taxpayer answered yes to Question 8 on Schedule B, he or she may be required to file Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts.  Form 3520 applies to several types of U.S. taxpayers, including those who received a distribution from a foreign trust and those who created or transferred money or property to a foreign trust.

The U.S. taxpayer may also be required to file Form 8938, Statement of Specific Foreign Financial Assets with his or her annual tax return.  Whether a taxpayer is required to file this form depends on where the taxpayer lives, the taxpayer’s filing status, and the value in the accounts.  For example, unmarried taxpayers living in the United States must file Form 8938 if the total value of your interest in the foreign trust is more than $50,000 on the last day of the tax year or more than $75,000 at any time during the tax year. The value of the interest in the foreign trust equals the value of all cash or other property distributed during the tax year to you as beneficiary plus a value indicated on the valuation tables under section 7520.

A U.S. taxpayer who transfers money or property to a foreign trust may also be required to file a Form 709, United States Gift (and Generation-Skipping Transfer) Tax Return.  Generally, a U.S. taxpayer who transfers money or property totaling more than $14,000 for the year must file a Form 709.  Form 709 is a separate tax return, which is not submitted with the taxpayer’s annual tax return.

Failure to comply with the above reporting requirements can result in steep penalties to the unwitting taxpayer.  Failure to file an FBAR may result in civil penalties for negligence, pattern of negligence, non-willful, and willful violations.  These penalties range from a high penalty for willful violations, equal to the greater of $100,000 or 50% of the balance in the account at the time of violation, to a low penalty of $500 for negligent violations.  For failing to file a correct Schedule B or Form 8938, the taxpayer could face a failure-to-file penalty of $10,000, criminal penalties, and if the failure to file results in underpayment of tax, an accuracy-related penalty equal to 40% of the underpayment of tax and a fraud penalty equal to 75% of the underpayment of tax.

Failure to file a correct and complete Form 3520results in an initial penalty of the greater of $10,000, 35% of the gross value of any property transferred to or distribution from a foreign trust, or 5% of the gross value of the portion of the trust’s assets treated as owned by the U.S. taxpayer.  An additional 5% penalty of any unreported foreign gifts may also apply for each month for which the failure to report continues.

Finally, failure to file a Form 709 may come with penalties for willful failure to file a return on time, willful attempt to evade or defeat payment of tax, and valuation understatements that cause an underpayment of the tax.  A 20% penalty of the tax underpayment may be imposed on both a substantial valuation understatement (the reported value of property listed on Form 709 is 65% or less of the actual value of the property) and a gross valuation understatement (the reported value listed on the Form 709 is 40% or less of the actual value of the property).

U.S. taxpayers who have an interest in a foreign trust would benefit from the experienced tax attorneys of the Law Office Of Jeffrey B. Kahn, P.C. representing you to avoid the pitfalls associated with failure to comply with the reporting requirements associated with having an interest in a foreign trust.

Description: Let the tax attorneys of the Law Offices Of Jeffrey B. Kahn, P.C. resolve your IRS tax problems, get you in compliance with your FBAR filing obligations, and minimize the chance of any criminal investigation or imposition of civil penalties.

Americans with Israeli Bank Accounts- Under Heightened Scrutiny in 2014

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Americans with Israeli bank or other financial accounts could face a tough tax season in 2014 if they do not come forward and disclose their assets to the IRS.  Recently, Israeli banks have come under increased scrutiny by the IRS in regards to disclosing the accounts of their American clients.  In particular, three Israeli banks- Bank Hapoalim, Bank Leumi and Mizrahi Tefahot- are under investigation by the Department of Justice.  To avoid prosecution, many other Israeli banks will begin turning over information as early as July 2014.

The prompt release of U.S. accountholder information by Israeli banks is a result of the IRS’s efforts to fully implement the 2010 Foreign Account Tax Compliance Act (“FATCA”) which requires foreign banks and financial institutions to report the assets of their American account holders.  FATCA was passed as part of the U.S. government’s effort to crack down on U.S. tax evaders.  Initially, the IRS concentrated its efforts on Swiss Banks.  However, in the past year, the IRS has been expanding its reach to other countries, particularly Israel.

As a result of this crackdown, some Israeli banks have been urging their American account holders to come forward and disclose their assets under the Offshore Voluntary Disclosure Initiative (OVDI).  In December 2013, Bank Leumi, the largest commercial Bank in Israel, sent out a letter to their American clients to come forward under the program.

U.S. taxpayers with account holdings should seriously consider coming forward and disclosing their assets to the IRS.  If you have never reported your foreign investments on your U.S. Tax Returns, the IRS has established the Offshore Voluntary Disclosure Initiative (OVDI) which allows taxpayers to come forward to avoid criminal prosecution and not have to bear the full amount of penalties normally imposed by IRS.

Despite the recent scrutiny by IRS on the Israeli bank, the attorneys with Law Offices Of Jeffrey B. Kahn, P.C. are still qualifying taxpayers with Israeli bank accounts for OVDI. With our expertise in Offshore Account Voluntary Disclosures, taxpayers should result in avoiding any pitfalls and gaining the maximum benefits conferred by this program.

Description: Let the tax attorneys of the Law Offices Of Jeffrey B. Kahn, P.C. resolve your IRS tax problems, get you in compliance with your FBAR filing obligations, and minimize the chance of any criminal investigation or imposition of civil penalties.

Report of Foreign Bank and Financial Accounts (FBAR) Filing Limits

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In addition to annual income tax forms, certain taxpayers are required to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (“FBAR”; previously called Form TD F 90-22.1).  All U.S. taxpayers who have an interest in, or signatory or other authority over a bank, securities or other similar foreign accounts must file an FBAR, if the aggregate value of the foreign accounts exceeds $10,000 at any time during the calendar year.  The $10,000 threshold value applies whether the taxpayer holds the financial accounts separately or jointly with another person or persons.

As of October 1, 2013 the FBAR form must be filed through the Financial Crimes Enforcement Network’s (FinCEN’s) Bank Secrecy Act E-Filing System on or before June 30th of the year following the calendar year being reported.  For example, to report foreign accounts held open in 2013, the taxpayer must file the FBAR by June 30, 2014.

U.S. taxpayers who have foreign financial accounts would benefit from the experienced tax attorneys of the Law Office Of Jeffrey B. Kahn, P.C. representing you to avoid the pitfalls associated with failure to comply with the reporting requirements associated with owing foreign financial accounts.

Description: Let the tax attorneys of the Law Offices Of Jeffrey B. Kahn, P.C. resolve your IRS tax problems, get you in compliance with your FBAR filing obligations, and minimize the chance of any criminal investigation or imposition of civil penalties.

“Quiet Disclosure” of Foreign Accounts- Not So Quiet As It Seems

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There are strong indications that going forward, the IRS will be cracking down more stringently on the practice of “quiet disclosures”.  Under a quiet disclosure, a taxpayer through normal IRS filing channels files new or amends past tax returns and FBAR’s to report previously unreported offshore accounts and foreign income in an attempt to avoid potential civil penalties and fines.

The danger in doing this, however, is that if the IRS discovers a quiet disclosure, the taxpayer will be exposed to higher civil penalties than he would have if he voluntarily came forward under the Offshore Voluntary Disclosure Initiative (OVDI).  The taxpayer might even be exposed to criminal prosecution.

The IRS has clearly indicated its disdain for those who make quiet disclosures instead of participating in OVDI and to discourage taxpayers from pursuing this route, the IRS has implemented procedures at the Service Centers to intercept those filings reporting foreign income for further review and investigation by the IRS.  Where a taxpayer has been discovered by IRS in this process, that taxpayer who made the quiet disclosure will not be eligible for the 27.5% offshore penalty.  Instead a larger penalty of 50% would apply.  Also, if appropriate, the IRS may recommend criminal prosecution to the Department of Justice.  The IRS does encourage those who have already quietly disclosed to come forward under the OVDI to avail themselves of the lower penalty rates and avoid potential harsher consequences.

If you have never reported your foreign investments on your U.S. Tax Returns or even if you have already quietly disclosed, you should seriously consider participating in the IRS’s Offshore Voluntary Disclosure Initiative (OVDI) which allows taxpayers to come forward to avoid criminal prosecution and not have to bear the full amount of penalties normally imposed by IRS.  Taxpayers who hire an experienced tax attorney in Offshore Account Voluntary Disclosures should result in avoiding any pitfalls and gaining the maximum benefits conferred by this program.

Description: Let the tax attorneys of the Law Offices Of Jeffrey B. Kahn, P.C. resolve your IRS tax problems, get you in compliance with your FBAR filing obligations, and minimize the chance of any criminal investigation or imposition of civil penalties.

Considerations in Opting Out of the OVDI

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IRS has established programs for taxpayers to voluntarily come forward and disclose unreported foreign income and foreign accounts under what the IRS calls the Offshore Voluntary Disclosure Initiative (OVDI).

On January 9, 2012 the IRS announced the terms of the 2012 OVDI which requires that taxpayers: (1) File 8 years of back tax returns reflecting unreported foreign source income; (2) Calculate interest each year on unpaid tax; (3) Apply a 20% accuracy-related penalty under Code Sec. 6662 or a 25% delinquency penalty under Code Sec. 6651; and (4) Apply up to a 27.5% penalty based upon the highest balance of the account in the past eight years.

In return for entering the offshore voluntary disclosure program, the IRS has agreed not to pursue charges of criminal tax evasion which would have resulted in jail time or a felony on your record; and other fraud and filing penalties including IRC Sec. 6663 fraud penalties (75% of the unpaid tax) and failure to file a TD F 90-22.1, Report of Foreign Bank and Financial Accounts Report, (FBAR) (the greater of $100,000 or 50% of the foreign account balance).

With taxpayers still facing a rather large penalty, taxpayers are torn on whether or not they should participate in OVDI or “Opt-Out”.

OVDI may not be perfect, but it is a finite way of getting beyond the fear of discovery and prosecution. Before our firm would engage in any discussion of opting-out with a client, we would first make sure that the Revenue Agent assigned to evaluate our client’s Civil Package has considered all of our arguments and positions to assure the lowest possible penalty or a taxpayer’s qualification for a lower OVDI penalty rate (such as 5% for inherited accounts).

When we know that we have done every possible within the confines of OVDI and the Revenue Agent has issued his or her final report, we would discuss then with our client the option of opting-out of OVDI.  There is much talk of opting-out but sparse data so far. The opt-out election is irrevocable and is typically made after the IRS has calculated a proposed miscellaneous offshore penalty. Keep in mind that from the time of registration into OVDI has occurred, at least a year has since past so if you have not yet registered into OVDI – registering for OVDI now still leaves much time before considering to opt-out.

From our experience, each person’s case must be looked at separately to determine if opting-out is the best option.  If you have no evidence of willfulness, the sheer numbers may make opting out attractive especially where the proposed OVDI penalty is in the hundreds of thousands of dollars.  But for those taxpayers whose proposed OVDI penalty is let’s say $80,000 or less, opting out probably can’t save you too much, especially if by opting out you end up with non-willful penalties which over a six-year period can equate to about the same amount as this $80,000 guideline amount referred herein.

From a broad perspective OVDI is predictable but opting out is much less so. As the above considerations reflect, think about your facts. Ask whether the potential risks and additional legal fees of opting out offset the potential rewards. Individual advice about the particular facts are important.

Description: Let the tax attorneys of the Law Offices Of Jeffrey B. Kahn, P.C. resolve your IRS tax problems, get you in compliance with your foreign account filing obligations, and minimize the chance of any criminal investigation or imposition of civil penalties.

 

Swiss Banks Rush to Meet U.S. Disclosure Deadline – Urge Their American Account Holders to Come Forward with Disclosure to the IRS

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The Swiss government has been urging about 300 Swiss banks to come forward and disclose their American account holdings to the U.S.   The deadline set by the U.S. Department of Justice (“DOJ”) for the Swiss banks to participate in a voluntary program whereby they disclose assets of their American clients was December 31, 2013.  By disclosing the assets and paying fines, the banks would be avoiding criminal prosecution.

In recent years, the U.S. has been cracking down on American tax evaders and the banks that help them.  In 2009, Swiss banking giant UBS admitted they were aiding tax evaders and paid out $780 million in a settlement with the U.S.  Another bank, Wegelin & Co., folded because of pressures from the DOJ investigation.

In turn, the Swiss banks have been pressuring their U.S. clients to come forward and disclose their assets to the IRS.  In December 2013, Swiss banks sent out letters to their American clients urging them to fess up.  The hope is that if more account holders come forward, the banks will pay less in fines and penalties.

Over 80% of Swiss Banks surveyed had stated that they have implemented the steps to participate in the DOJ Disclosure Program and that they are sending information on U.S accountholders to the DOJ.

If you have never reported your foreign investments on your U.S. Tax Returns, the IRS has established the Offshore Voluntary Disclosure Initiative (OVDI) which allows taxpayers to come forward to avoid criminal prosecution and not have to bear the full amount of penalties normally imposed by IRS.  Taxpayers who hire an experienced tax attorney in Offshore Account Voluntary Disclosures should result in avoiding any pitfalls and gaining the maximum benefits conferred by this program.

Let the tax attorneys of the Law Offices Of Jeffrey B. Kahn, P.C. resolve your IRS tax problems, get you in compliance with your FBAR filing obligations, and minimize the chance of any criminal investigation or imposition of civil penalties.

U.S. Taxpayer Worldwide Income Reporting Requirements

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Many U.S. taxpayers do not realize that they must report their worldwide income, regardless of whether they are living in the U.S. or abroad.  If you are a U.S. Citizen or resident alien, you must report your worldwide income from whatever source, subject to the same income tax filing requirements that apply to U.S. Citizens or resident aliens living in the U.S.

When a U.S. taxpayer owns or has signatory authority over a foreign account, the reporting requirements become more complex.   All U.S. taxpayers who have an interest in, or signatory or other authority over a bank, securities or other similar foreign accounts must file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR), if the aggregate value of the foreign accounts exceeds $10,000 at any time during the calendar year.  As of October 1, 2013 the FBAR form must be filed through the Financial Crimes Enforcement Network’s (FinCEN’s) Bank Secrecy Act E-Filing System on or before June 30th of the year following the calendar year being reported.  For example, to report foreign accounts held open in 2013, the taxpayer must file the FBAR by June 30, 2014.

In addition to filing an FBAR form, the U.S. taxpayer must follow certain reporting requirements on his or her annual tax return.  First, the U.S. taxpayer must include a completed Schedule B, Interest and Ordinary Dividends, with his or her annual tax return.  On Schedule B, the taxpayer will complete Part III, Foreign Accounts and Trusts, which asks whether, at any time in the year, the taxpayer had a financial interest in or signatory authority over a foreign financial account.  Schedule B also asks whether the taxpayer is required to file an FBAR, and if so, in which foreign country the financial account was located.

The U.S. Taxpayer may also be required to file Form 8938, Statement of Specific Foreign Financial Assets with his or her annual tax return.  Whether a taxpayer is required to file this form depends on where the taxpayer lives, the taxpayer’s filing status, and the value in the accounts.  For example, unmarried taxpayers living in the United States must file Form 8938 if the total value of your specified foreign financial assets is more than $50,000 on the last day of the tax year or more than $75,000 at any time during the tax year.

Failure to comply with the above reporting requirements can result in steep penalties to the unwitting taxpayer.  Failure to file an FBAR may result in civil penalties for negligence, pattern of negligence, non-willful, and willful violations.  These penalties range from a high penalty for willful violations, equal to the greater of $100,000 or 50% of the balance in the account at the time of violation, to a low penalty of $500 for negligent violations.  For failing to file a correct Schedule B and Form 8938, the taxpayer could face a failure-to-file penalty of $10,000, criminal penalties, and if the failure to file results in underpayment of tax, an accuracy-related penalty equal to 40% of the underpayment of tax and a fraud penalty equal to 75% of the underpayment of tax.

U.S. taxpayers who have foreign financial accounts would benefit from the experienced tax attorneys of the Law Office Of Jeffrey B. Kahn, P.C. representing you to avoid the pitfalls associated with failure to comply with the reporting requirements associated with owing foreign financial accounts.

Let the tax attorneys of the Law Offices Of Jeffrey B. Kahn, P.C. resolve your IRS tax problems, get you in compliance with your FBAR filing obligations, and minimize the chance of any criminal investigation or imposition of civil penalties.

 

Eliminating Tax Penalties Due to Reasonable Cause

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If you have made a mistake on your tax return that is later discovered by the IRS, you will be charged interest on the amount you owe. In addition, the IRS has the discretion to assess penalties requiring you to pay extra. But this doesn’t mean that you will have to pay these penalties. Working with a tax lawyer in Los Angeles or elsewhere can help in getting the penalties reduced or even dropped.

About one-third of all IRS penalties are abated and your odds of having your penalties dropped are much higher if you work with a tax attorney on your case. In order to convince the IRS to remove the penalties they have imposed, you need to convince them of special circumstances that lead to “reasonable cause” for you to not have made a correct filing initially.

This goes beyond just admitting that you made an honest mistake. Here are a few of the scenarios that the Law Offices Of Jeffrey B. Kahn, P.C.  know that the IRS will consider to be reasonable cause for an erroneous tax filing:

  • A death or serious illness in the family.
  • Incorrect advice given by an IRS agent in person or over the phone.
  • The loss of records because of a fire or natural disaster.
  • An error made by your tax preparer.

If you feel that you are being unfairly punished for a problem with a tax filing that was beyond your control, your best bet is to contact an IRS attorney from our firm who can review the facts in your case.

An experienced attorney with the Law Offices Of Jeffrey B. Kahn, P.C. may be able to help you get your tax penalties reduced or eliminated. Learn about the circumstances a tax attorney can use to plead your case with the IRS.