“ … a requesting spouse may avoid joint and several liability of a joint return by claiming relief under I.R.C. § 6015(b), (c), and/or (f). The three types of relief available are as follows: 1. Full or apportioned relief under I.R.C. § 6015(b); 2. Proportionate relief under I.R.C. § 6015(c); and 3. Equitable relief under I.R.C. § 6015(f).”
“Highlights from November 20, 2015 Proposed Regulations - The proposed regulations are intended to reflect: (1) the changes Congress made in 2006 to section 6015 (jurisdiction of U.S. Tax Court to determine appropriate relief under I.R.C. §6015(f), equitable relief); (2) additional guidance on the meaning of res judicata and the I.R.C. §6015(g)(2) exception therefrom (examples are provided in the proposed regulations); (3) definition of unpaid/underpaid tax for purposes of I.R.C. §6015(f); (4) “provide detailed rules regarding credits and refunds in innocent spouse cases”; (5) penalties and interest are not separable items in the case of underpayment; (6) revisions to the regulations on prohibition on collection and suspension of the statute of limitation on collection.”
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Frank Agostino is the president of Agostino & Associates, P.C., a law firm in Hackensack, New Jersey specializing in civil and white collar criminal litigation, tax controversies and tax planning. Prior to entering private practice, he was an attorney with the Internal Revenue Service’s District Counsel in Springfield, Illinois and Newark, New Jersey; he also served as a Special Assistant United States Attorney, where he prosecuted primarily criminal tax cases.
Dennis Brager if the founder of the Brager Tax Law Group – a worldwide practice limited to representing clients having criminal and civil disputes with the IRS, the California Franchise Tax Board, the State Board of Equalization and the Employment Development Department. He is a former Senior Trial Attorney for the Internal Revenue Service’s Office of Chief Counsel. Mr. Brager is a California State Bar Certified Tax Specialist.
Agenda
Faculty
Dennis Brager
Brager Tax Law Group
- Founder of the Brager Tax Law Group – a worldwide practice limited to representing clients having criminal and civil disputes with the IRS, the California Franchise Tax Board, the State Board of Equalization and the Employment Development Department
- Former Senior Trial Attorney for the Internal Revenue Service’s Office of Chief Counsel
- California State Bar Certified Tax Specialist
- Frequent lecturer at the UCLA Tax Controversy Institute and University of Southern California
- Appeared on ABC’s Television show Good Morning America, Fox Business News, KFWB Money 101, and KABC’s The Larry Elder Show
- Author of articles that have appeared in California Lawyer, Daily Journal, Taxation for Lawyers, Los Angeles Lawyer, The Consumer Advocate, Family Law News, California Tax Lawyer, Journal of Tax Practice and Procedure, Journal of Tax Investments, and Marijuana Venture
- Quoted as a tax expert by Business Week, The Daily Journal, The Daily Beast, USA Today, Tax Analyst, The Chicago Tribune, CNN Money, Bloomberg BNA, Accounting Today, Tax Notes Today, and The National Law Journal
- Former chair of both the Tax Compliance, Procedure and Litigation Committee of the Los Angeles County Bar Association and the California State Bar, Tax Procedure and Litigation Committee
- Can be contacted at 310-208-6200 or www.bragertaxlaw.com
Frank Agostino
Agostino & Associates
- President of Agostino & Associates, a law firm in Hackensack, New Jersey specializing in civil and white collar criminal litigation, tax controversies and tax planning
- Prior to entering private practice, he was an attorney with the Internal Revenue Service’s District Counsel in Springfield, Illinois and Newark, New Jersey; he also served as a Special Assistant United States Attorney, where he prosecuted primarily criminal tax cases
- Frequent speaker and author on tax controversy and litigation matters
- Serves on the advisory board of the Journal of Tax Practice and Procedure; actively involved with the American Bar Association and the New York County Lawyers’ Association
- President of the Taxpayers Assistance Corp., which provides tax and legal advice to low income taxpayers in the NY/NJ area
- J.D. degree, New York Law School; B.A. degree, City College of New York; LL.M. degree in taxation, New York University School of Law
- Can be contacted at 201-488-5400 or [email protected]
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