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January 2012:   Bad news for taxpayers, as well as those who don't pay their taxes!  The Internal Revenue Service annual report shows that the numer of audits were up again last year, as were the number of levies and seizures.  The IRS believes that there is only approximately 85 percent compliance among American taxpayers, and is flexing its enforcement muscles as expected.  Because of this noncompliance by taxpayers, the IRS believes there is a $450 Billion tax gap annually.

December 2011: Are you thinking about selling your business? Buying a business? Using a business broker? So many clients go through a complex learning process when considering the countless factors involved in acquiring or selling an existing business. A recent New York Times column lists several blogs and sources for good information to help business owners (and potential owners) make the right decision for them. Remember to contact Mr. Cohen prior to signing any type of letter of intent or purchase contract.

November 2011:  Mr. Cohen recently secured the release of a salary and investment account levy from the IRS for $2.4 million in less than a week.  He was able to convince the IRS to take other collateral, while offering proof that the client/Taxpayer owed only a fraction of what the IRS claimed.  The Taxpayer now has his funds back, his reputation restored, and his account with the IRS is corrected and in good standing.

November 2011:  We just successfully completed an Offer in Compromise for a client with the Georgia Department of Revenue.  While this was a big relief for the client, who did settle for "pennies on the dollar," we continue to be very skeptical in filing such Offers.  The vast majority of IRS and Georgia Offers are rejected, and we remind clients that the television advertisements you constantly see are extremely misleading.

October 2011:  Many businesses incorrectly treat their employees as independent contractors, or "1099 employees," thereby avoiding paying certain social security taxes on their behalf.  An audit by the IRS can result in painful penalties for such worker misclassification.  In general, if your "contractors" work only for you or on your projects or at your direction, they likely should be treated for tax purposes as employees, and taxes withheld from their paychecks.  The IRS has announced a new program allowing companies to change their worker classification and avoid most penalties and back taxes.  Call us to discuss how your company might take advantage of the Voluntary Classification Settlement Program.

September 2011:  IRS criminal investigations have significantly increased!  A recent report shows that the Criminal Investigation Division began over 12 percent more investigations of taxpayers last year alone.  The government's conviction/incarceration rate remains at over 80 percent.  Remember, do not speak with a Special Agent, and call our office at once if you are contacted by the Criminal Investigation Division.

August 2011:  Good news for those taxpayers/clients who owe taxes to the Internal Revenue Service.  The IRS has reduced the annual interest rate on back taxes down to three percent!  Please remember, however, that the Georgia Department of Revenue does not let market conditions affect their interest rate on past due taxes:  the Georgia interest rate remains at twelve percent.

July 2011:  The Internal Revenue Service has loosened the restrictions for Innocent Spouse cases.  No longer will our clients who want to be relieved of the tax liabilities of their former spouses be forced to file their Innocent Spouse claims within two years of the first IRS collection notice. Potential clients should of course contact us immediately if they feel something is not right with their spouse's tax returns or financial dealings.

July 2011: The Fulton County Daily Report, the major legal newspaper for the Atlanta Metropolitan area, has published an article on our recent victory against the Georgia Department of Revenue.

June 2011: MAJOR NEWS FOR COHEN, COOPER, ESTEP & ALLEN: After a three year battle with the Georgia Department of Revenue, Mr. Cohen won a victory in Fulton County Superior Court. The judge held that the Georgia DOR may not assess the Trust Fund Recovery Penalty against our client who managed, but did not control, a restaurant. In addition to this being a major tax savings to our client, it showed that it is possible to successfully stand up to unfair collection tactics by the Government.

June 2011: For those who have foreign/offshore bank accounts and wish to get back into the system without criminal repercussions and huge civil penalties, the IRS has extended the August 31 deadline for the 2011 Offshore Voluntary Disclosure Initiative by thirty days. We have represented several people in successfully taking advantage of this limited time offer.

May 2011: The Innocent Spouse provisions of the tax code are sometimes the only way a divorced or widowed person can escape from the tax liabilities created by their divorced or deceased spouse. Many attorneys believe, however, that the IRS unfairly applies this law to make it too restrictive, thereby saddling truly "innocent" spouses with tax liabilities that they should not in all fairness have to pay. Several U.S. Senators have recently signed a letter to the IRS Commissioner asking that the IRS review its Innocent Spouse regulations. We of course remain hopeful that the Innocent Spouse rules will someday become easier to qualify under, and will continue to press hard to get relief for our clients using existing regulations.

May 2011: Beware of tax resolution companies. Countless clients of our firm have previously hired the firms they see advertising on television, only to be disappointed with their lack of professionalism and level of communication. A popular tax resolution company has just been successfully sued by the Texas Attorney General.

April 2011: The Internal Revenue Service has announced that audits of taxpayers are up this year. The Wall Street Journal on April 4 reported that audits were up significantly during the most recent fiscal year, especially for six-figure earners.

March 2011: Due to the fact that the Georgia Department of Revenue has garnished the wages and seized bank accounts of so many Georgians, and has not instituted a workable repayment program, Mr. Cohen recently wrote a letter to Georgia's new Commissioner of Revenue, offering suggestions to make the program fair to Georgia taxpayers.

February 2011: The Internal Revenue Service has recently issued a new Offshore Voluntary Disclosure program. This will encourage taxpayers with foreign bank accounts to disclose the accounts, pay a penalty, and get back into the system without the fear of criminal prosecution. Please call Mr. Cohen to discuss how you can take advantage of this new program.

Jeffrey L. Cohen
News & Client Updates

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Jeffrey L. Cohen, Attorney at Law
3330 Cumberland Boulevard S.E.,
Suite 600
Atlanta, GA 30339
Phone: 770-884-7215
Toll Free: 888-319-6861
Fax: 404-816-8900
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