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  1. Services

    … NEVER be shared with the IRS. ‌ Tax Attorney William D. Hartsock, Tax Attorney Inc … to file an FBAR every year by June 30th. This is an information return only, meaning an FBAR does not incur tax … level.   ‌ Tax Litigation Tax litigation is requires in depth …

  2. Tax Litigation After the Appeals Process

    Tax Litigation After the Appeals Process When … and evidentiary rules. In addition to presenting the information thoroughly and concisely, the case the … client privilege call (858)481-4844 or fill out the contact form found on this page. …

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  3. Personal IRS Audit FAQs

    … below to get the answer to your question directly from tax attorney William Hartsock, Esq: Find answers to the … and your business expenses are legitimate. For more information about your situation and whether or not you need … attorney, documents that are prepared in anticipation of litigation. You're not required to turn those over to the …

  4. Jurisdictional and Procedural Requirements in Deficiency Litigation

    Jurisdictional and Procedural Requirements in Deficiency Litigation When contemplating filing a … 90-Day Filing Period The first step in a tax deficiency litigation is always the statutory notice … Category Tax Litigation Information and Advice …

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  5. Refund Claims Made in Tax Litigation

    Refund Claims Made in Tax Litigation Sometimes, it is in the best … period of limitations for filing a refund claim. What Information Should be Included in a Refund Claim for …

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  6. Limitations on the Use of Foreign-Based Documentation in Tax Litigation

    Limitations on the Use of Foreign-Based Documentation in Tax Litigation The Internal Revenue Code … a specific definition, meaning a request made after an “information document request” has failed to produce the …

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  7. Statute of Limitations on Filing Tax Refund Claims

    Statute of Limitations on Filing Tax Refund Claims A taxpayer who wishes … If the taxpayer elects to file a lawsuit and pursue tax litigation for refund after filing a written refund claim, … Blog Category Tax Appeal Information & Advice From The Tax Lawyer …

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  8. Tax Crimes Defense Strategies: Dealing with Goverment Agents

    Tax Crimes Defense Strategies: Dealing with Goverment Agents … documents may be prepared with knowledge of pending tax litigation before or after the service of the subpoena. … consideration. The downside to this approach is that any information provided to these entities for consideration of …

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  9. Things a Taxpayer Should Know in Criminal Investigations

    … work product, and Fifth Amendment privileges in criminal tax cases. However, these protections can be lost if the … taxpayers and counsel should also take steps to prevent information from being revealed through careless disclosure. … or incurred for representation in criminal or civil tax litigation are deductible if they are ordinary and necessary …

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