NYC Tax Advocates

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Specializing in IRS and NYS Tax Representation. Workers Compensation Audits, Payroll, Sales and Income Tax representation for Businesses, Individuals, Restaurants and Construction Companies. Civil and Criminal Workers Comp Audit representation includes: NYSIF Examinations, Premium Disputes, Employee Misclassification, Underreporting, Unreported Income, and Failure to Keep Accurate Payroll Records.
Showing posts with label #We Solve Tax Problems. Show all posts
Showing posts with label #We Solve Tax Problems. Show all posts

Friday, August 9, 2019

Do NYS Tax Enforcement Agents Play Fast and Loose with the Rules? "SOME DO" says David Selig of Selig & Associates



Two weeks ago the State levied a business-owner’s bank account because he owed about $17,000 in unpaid sales taxes. The next day the business-owner came to our office and hired us to negotiate an affordable re-payment plan between him and the State.  

Two days later I entered the business-owner into an excellent installment agreement, and as a matter of procedure, provided the Agent [who had issued the bank levy] with the exact amount of money that that was in the bank account, so that these funds could be applied to the taxpayer’s debt. 

So far so good . . . Not so fast Skippy

That’s when things went south. The Agent said the the business-owner would have to call her himself and that she and the business-owner needed to have a “conference-call” with the bank. I refused and explained to the Agent that an Accountant and Attorney represent the business-owner and that under no circumstances would our client call her. 

The Agent was adamant and demanded that I give her the business-owner’s telephone number so that she could speak with him directly. Again, I refused and explained to her that an Accountant and Attorney represent the business-owner and that she was not to contact him directly. Whereupon the Agent said “the installment agreement is only pending” that it hadn’t been approved yet, and  some other not so thinly veiled threats. 

I had heard enough and asked to speak with her supervisor. The Agent refused and said the supervisor would agree with her. I said “maybe so” but that I still want to speak with her. The Agent said, “she’s not available”; that her supervisor was very busy, and that she would send her supervisor an email asking her to call me.  That's when I asked the Agent for her supervisor’s name and telephone number. The Agent angrily refused to provide me with either and said, “She’ll call you” then abruptly hung up.  

Well, it’s been over a week and still no call - which begs the question, is this just a poorly trained Agent? Or alternatively, does the State in its zeal to collect and cajole taxpayer’s into compliance, condone and encourage this sort low level nonsense. 

Selig & Associates, we take a practical approach to problem solving and strive to obtain the best possible outcome for our clients

We successfully resolve most IRS and New York State Tax problems including suspended Drivers Licenses and Passports. Specializing in large dollar Payroll, Sales and Income Tax Representation for Individuals, Professional Practices and Businesses. 

We negotiate excellent Payment Plans, Audits, Offers in Compromise, Payroll & Trust Fund Recovery Penalties, and most other tax issues. Do you have Unfiled Tax Returns? We can have them prepared and filed for you within 48 hours, guaranteed. Call (212) 974-3435 or contact us online. 

Same day and emergency appointments are available in our New York City offices. Schedule a Free and Legally Privileged Consultation with a Federal Tax Practitioner and Attorney by calling (212) 974-3435 or contact us online.

Tuesday, August 6, 2019

IRS sends letters to virtual currency owners "pay back taxes and file amended returns" criminal prosecution imminent – better call SELIG & Associates


The Internal Revenue Service has begun sending letters to taxpayers with virtual currency transactions that potentially failed to report income and pay the resulting tax from virtual currency transactions or did not report their transactions properly. "Taxpayers should take these letters very seriously by reviewing their tax filings and when appropriate, amend past returns and pay back taxes, interest and penalties," said IRS Commissioner Chuck Rettig. "The IRS is expanding our efforts involving virtual currency, including increased use of data analytics. We are focused on enforcing the law and helping taxpayers fully understand and meet their obligations." The IRS started sending the “educational letters” to taxpayers last week. By the end of August, more than 10,000 taxpayers will receive these letters. The names of these taxpayers were obtained through various ongoing IRS compliance efforts. For taxpayers receiving an educational letter, there are three variations: Letter 6173, Letter 6174 or Letter 6174-A, all three versions strive to help taxpayers understand their tax and filing obligations and how to correct past errors. Taxpayers are pointed to appropriate information on IRS.gov, including which forms and schedules to use and where to send them. Last year the IRS announced a Virtual Currency Compliance campaign to address tax noncompliance related to the use of virtual currency through outreach and examinations of taxpayers. The IRS will remain actively engaged in addressing non-compliance related to virtual currency transactions through a variety of efforts, ranging from taxpayer education to audits to criminal investigations. Virtual currency is an ongoing focus area for IRS Criminal Investigation. IRS Notice 2014-21 (PDF) states that virtual currency is property for federal tax purposes and provides guidance on how general federal tax principles apply to virtual currency transactions. Compliance efforts follow these general tax principles. The IRS will continue to consider and solicit taxpayer and practitioner feedback in education efforts and future guidance. The IRS anticipates issuing additional legal guidance in this area in the near future. Taxpayers who do not properly report the income tax consequences of virtual currency transactions are, when appropriate, liable for tax, penalties and interest. In some cases, taxpayers could be subject to criminal prosecution.

True Tax Help we successfully resolve all IRS and New York State tax problems including suspended Drivers Licenses and Passports. We specialize in unpaid payroll, sales and income taxes and negotiate excellent payment plans for businesses and individuals. To schedule a free consultation with a results driven Federal Tax Practitioner and Attorney call  (212) 974-3435 or contact us online.

Thursday, August 1, 2019

4 Counts of 3rd Degree Failure to Pay Taxes, 4 Counts of 3rd Degree Filing of a Fraudulent Tax Return, and 1 Count of 4th Degree Falsifying Records



Grand Jury returns 11-count indictment against a former bookkeeper who stole more than $223,000 from her employer (between January 2012 and June 2017). The indictment charged her with one count of second degree Theft of Movable Property, one count of second degree Computer Criminal Activity, four counts of third degree Failure to Pay Taxes, four counts of third degree Filing of a Fraudulent Tax Return, and one count of fourth degree Falsifying Records. If she’s convicted of either of the second degree offenses, she'll face a maximum of 10 years in state prison. The third degree charges each have a maximum 5-year exposure in state prison. The fourth degree charge has a maximum exposure of 18 months in state prison. Despite these charges, every defendant is presumed innocent, unless and until found guilty beyond a reasonable doubt, following a trial at which the defendant has all of the trial rights guaranteed by the U.S. Constitution and State law. (She'd better call Selig & Associates)  

We Take a Practical Approach to Problem Solving and Strive to Obtain the Best Possible Outcome for our Clients

Effective Tax Advocacy we successfully resolve most IRS and New York State tax problems including suspended Drivers Licenses and Passports. We specialize in unpaid payroll, sales and income taxes and negotiate excellent payment plans for businesses and individuals. To schedule a free consultation with a results driven Federal Tax Practitioner and Attorney please call us directly at (212) 974-3435.

Your Serious Tax Problem Deserves Our Serious Attention 

Trust Selig & Associates our offices are conveniently located in New York City and we meet with each and every client personally. To schedule a free legally privileged consultation with a Federal Tax Practitioner CPCU and Attorney please call us directly at (212) 974-3435. *Same day and emergency appointments are available upon request. 

Our Hard Work, Purpose and Persistence Assures Your Success

Insurance Claims Specialists we settle insured property damage claims in the shortest amount of time and at the least cost to the policyholder and insurance company. Insurance litigation is costly and time consuming. Accordingly we provide policyholders with a cost effective alternative to litigation. Commercial and residential insurance representation includes: Environmental Damage, Mold (removal & remediation) Fire, Business Interruption, Burglary, Vandalism, Windstorm and Water Damage. For additional assistance please call us at (212) 974-3435. 

Tuesday, July 30, 2019

NYS Tax Department Doesn’t Want Taxpayers to be Represented by Lawyers and Accountants



On June 3rd 2019 the New York State Department of Taxation and Finance published a online article entitled “Resolve Your Tax Debt Directly with the Tax Department” subtitled “Taxpayers can save time and money by contacting a Tax Department representative themselves” 

Not surprisingly, the Tax Department is actively encouraging taxpayers to “work directly with New York State” without the aid of a tax attorney or accountant. 

The article invites taxpayers to call the State directly to: pay their balance in full; to set up a monthly payment plan, and to “discus their debt” with a State representative (who is in reality a Civil Enforcement Agent with the power to levy your bank account and garnish your wages). The article then quotes the Executive Deputy Commissioner of Taxation and Finance Andrew Morris, who says: “Taxpayers don’t need to hire outside help or enlist the services of a third party to settle their tax debt” and similar self-serving sentiments. 

But conspicuously absent from Mr. Morris’s lopsided observations are the many pitfalls that await these unsuspecting callers. For example, the State claims it will not levy certain exempt funds, e.g. Social Security, public assistance, alimony, child support, unemployment, disability, workers compensationand pensions. Unfortunately they neglect to mention that there is no protection once these so-called “exempt funds” are deposited into a bank account. 

In fact the State can and will seize your entire bank account. And after your entire bank account has been seized the State frequently refuses to grant taxpayers so much as a partial release to pay for food, diapers, medication and health insurance. 

As for “payment plans” the State has 20 years to collect on tax debts - but that doesn’t stop them from demanding taxpayers make a “good faith deposit” and agree to full pay their debt in 24 to 36 months *This unnecessary time requirement is why the vast majority of taxpayer negotiated payment plans default. And when a taxpayer defaults (as most do) he or she is punished with even more levies and tougher payment terms. 

Lastly, taxpayers have rights that must be properly asserted within a prescribed period of time (known colloquially as the doctrine of “use it or lose it”).  And whether you like it or not, the State has no obligation to tell you your legal rights and possible options. Meaning, when the time to contest an erroneous tax liability expires, the debt becomes “fixed and final” and you're stuck with it. 

In conclusion, I suggest readers consider the severity of their debt and the likely consequences they will encounter before deciding to “go it alone”. 


We take a practical approach to problem solving and strive to obtain the best possible outcome for our clients.

Effective Tax Advocates we successfully resolve most IRS and New York State tax problems including suspended Drivers Licenses and Passports. We specialize in unpaid payroll, sales and income taxes and negotiate excellent installment agreements for businesses and individuals. To schedule a free consultation with a results driven Federal Tax Practitioner and Attorney please call us directly at (212) 974-3435.

Large Insurance Claims we settle insured property damage claims in the shortest amount of time and at the least cost to the policyholder and insurance company. Insurance litigation is costly and time consuming. Accordingly we provide policyholders and their insurance companies with a cost effective alternative to litigation. Commercial and residential insurance representation includes: Environmental Damage, Mold (removal & remediation) Fire, Business Interruption, Burglary, Vandalism, Windstorm and Water Damage.  

Trust Selig & Associates our offices are conveniently located in New York City and we meet with each and every client personally. To schedule a free legally privileged consultation with a Federal Tax Practitioner CPCU and Attorney please call us directly at (212) 974-3435.



  

Thursday, July 11, 2019

Man Pleads Guilty to Payroll Tax Fraud Failed to Pay IRS $1 Million in Employment Taxes & Employee Withholdings


A computer software development company owner pleaded guilty today to failing to account for and pay over employment taxes withheld from his employees’ wages announced Principal Deputy Assistant Attorney General Richard E. Zuckerman of the Justice Department’s Tax Division and U.S. Attorney R. Trent Shores for the Northern District of Oklahoma. 
According to documents and information provided to the Court, as the owner and operator of Tulsa-based Zealcon Corporation, Earenest J. Grayson Jr. was responsible for withholding, accounting for and paying over to the Internal Revenue Service (IRS) payroll taxes and withholdings due on the wages paid to Zealcon employees. For the period, January 2014 through June of 2016, Grayson intentionally caused a total tax loss of more than $1 million by intentionally not paying to the IRS income and social security taxes withheld from Zealcon employees’ wages and social security taxes due from Zealcon on those wages.
“Failing to account for or pay payroll taxes is not acceptable,” said Principal Deputy Assistant Attorney General Zuckerman of the Justice Department’s Tax Division. “The Department of Justice, working with the IRS, will ensure that our tax system is fairly enforced throughout the country.”
“Earenest Grayson is a dishonest employer who cheated both his employees and the United States government of more than $1,000,000 in stolen payroll taxes. Some of those taxes were payments for the Social Security and Medicare coverage of the employees,” said U.S. Attorney Trent Shores. “I hope Mr. Grayson’s potential prison sentence will dissuade other business owners from trying to cheat the system. Millions of honest small businesses pay their fair share of taxes to finance government operations as well as Social Security and Medicare for the elderly. Unfortunately, Mr. Grayson’s choice not to do so has subjected him to criminal penalties.”
United States District Court Judge Claire V. Eagan scheduled Grayson’s sentencing for Oct. 3, 2019. 
Selig & Associates is a boutique Tax Representation and Insurance Claims settlement firm in New York City. To schedule a legally privileged consultation with a Federal Tax Practitioner CPCU and Attorney, please call us directly at (212) 974-3435. 

We take a practical approach to problem solving and strive to obtain the best possible outcome for our clients.

Effective Tax Advocacy We successfully resolve civil and criminal tax problems including suspended Drivers Licenses and Passports. We provide practical solutions to difficult IRS and State tax problems. Specializing in unpaid sales and payroll taxes. We negotiate affordable installment agreements and if you have missing or unfiled tax returns, we can have them prepared and filed for you within 48 hours guaranteed. For immediate assistance, call us directly at (212) 974-3435 or contact us online. 

Insurance Claims We settle insured property damage claims in the shortest amount of time and at the least cost to the policyholder and insurance company. Insurance litigation is costly and time consuming. Accordingly, we provide policyholders and insurance companies with a cost effective alternative to litigation. Commercial and residential insurance representation includes: Environmental Damage, Mold (removal & remediation) Fire, Business Interruption, Burglary, Vandalism, Windstorm and Water Damage.  

For more information about our Tax and Insurance Claims settlement services or to schedule a FREE consultation, call (212) 974-3435 or contact us online. 



Tuesday, July 2, 2019

Can NY State Suspend My Drivers License for Unpaid Taxes? (Yes)





If your drivers' license has been suspended for unpaid taxes, we can help. New York State can suspend your drivers' license if you owe $10,000 or more in taxes, penalties and interest. See: New York Tax Law Section 171-v. Call (212) 974-3435 for immediate assistance. 


Selig & Associates is a Tax Representation and Insurance Claims settlement firm in New York City. Same day and emergency appointments are available Monday through Friday. To schedule a legally privileged consultation call (212) 974-3435 or contact us online. 

We successfully resolve civil and criminal tax problems including suspended Passports and Drivers Licenses. Specializing in unpaid income, sales and payroll taxes. We provide practical solutions to difficult tax problems. For example, we negotiate affordable installment agreements, and if you have missing or unfiled tax returns, we can have them prepared and filed for you within 48 hours guaranteed. For immediate assistance call (212) 974-3435 now. 

Is your Insurance Company treating you unfairly?  Have they offered you substantially less than your claim is worth? If the answer is yes, then call us directly. We successfully settle most first-party insurance claims without ever having to go to court. Commercial and residential insurance representation includes: Environmental Damage, Mold Removal, Remediation & Restoration claims, Fire, Business Interruption, Burglary, Vandalism, Windstorm and Water Damage. To consult with us personally call (212) 974-3435 or contact us online. 

Our mission is to identify and obtain the best outcome through transactional negotiations. We take a practical approach to problem solving and continuously evaluate the likelihood of success, the potential consequences, and the costs associated with taking, or failing to take a particular action. For additional information about our services call (212) 974-3435. 
   

Thursday, June 27, 2019

NEW YORK'S (shameful) 2016 FINANCIAL CONDITION REPORT




2016 FINANCIAL CONDITION REPORT

Public Welfare


Recipients of Public Assistance and Food Stamps
Enrollment in Public Assistance Increases Slightly for the First Time in Three Years
  • Family Assistance provides up to 60 months of cash assistance to eligible needy families; Safety Net Assistance provides cash or non-cash assistance to eligible single adults, childless couples, persons who have exceeded the 60-month limit on family assistance, children living apart from adult relatives and certain other individuals.
  • Public assistance enrollment in the State increased for the first time in three years, largely due to higher Safety Net Assistance (SNA) enrollment in New York City. Enrollment decreased in areas outside of New York City for the first time in eight years.
  • Compared to last year, the average monthly number of recipients of public assistance in:
    • New York State increased by 4,498 (0.8 percent) to 572,720;
    • New York City increased by 17,509 (5.2 percent) to 356,350; and
    • areas outside New York City decreased by 13,011 (5.7 percent) to 216,370.
  • Overall Family Assistance (FA) enrollment decreased by 3.0 percent for the second consecutive year, while overall SNA enrollment increased for the second consecutive year, but at a rate—3.8 percent—that was nearly four times higher than in State Fiscal Year 2014-15. Enrollment in FA and SNA increased in New York City, but decreased in areas outside of New York City. SNA is largely funded by the State and the counties, while FA is funded by the federal government.
Public Assistance Expenditures by Source
Spending for Public Assistance Continues to Increase, But at a Slower Rate
  • For the fourth consecutive year, public assistance spending increased, but by less than 1 percent and mainly because of an increase in SNA expenditures in New York City. The increase in public assistance expenditures continues the program’s recent spending growth, but it is occurring at a slower rate than in any of the last three years.
  • Compared to last year, public assistance expenditures in:
    • New York State increased by $4.3 million (0.2 percent) to $2.24 billion;
    • New York City increased by $50.3 million (3.8 percent) to $1.39 billion; and
    • areas outside New York City decreased by $46.0 million (5.1 percent) to $848.0 million.
  • SNA expenditures increased while FA expenditures decreased. For New York City, higher SNA expenditures more than offset lower FA expenditures. SNA expenditures accounted for 64.3 percent of total public assistance spending.
  • Compared to last year, SNA expenditures in:
    • New York State increased by $36.7 million (2.6 percent) to $1.44 billion;
    • New York City increased by $54.6 million (6.0 percent) to $968.8 million; and
    • areas outside New York City decreased by $17.8 million (3.6 percent) to $472.3 million.
  • Compared to last year, FA expenditures in:
    • New York State decreased by $32.4 million (3.9 percent) to $799.4 million;
    • New York City decreased by $4.3 million (1.0 percent) to $423.7 million; and
    • areas outside New York City decreased by $28.2 million (7.0 percent) to $375.7 million.
  • Child Care Block Grant subsidies for low-income families transitioning from public assistance increased by $33.3 million (3.4 percent) to $1.01 billion. These subsidies are financed by a combination of federal, State and local sources.
Child Care Block Grant (CCBG) Annual Commitments
SNAP Enrollment Decreases for Second Consecutive Year; Spending Decreases for Third Straight Year
  • Enrollment in the State’s Supplemental Nutrition Assistance Program (SNAP) decreased for the second consecutive year, following more than a decade of steady growth. SNAP, formerly known as the Food Stamp Program, is funded by the federal government.
  • Compared to last year, the average monthly number of recipients of SNAP in:
    • New York State decreased by 73,197 (2.4 percent) to 3.0 million;
    • New York City decreased by 47,542 (2.7 percent) to 1.69 million; and
    • areas outside New York City decreased by 25,655 (1.9 percent) to 1.31 million.
  • Expenditures for SNAP decreased for the third consecutive year.
  • Compared to last year, SNAP expenditures in:
    • New York State decreased by $110.6 million (2.2 percent) to $5.0 billion;
    • New York City decreased by $68.8 million (2.3 percent) to $2.97 billion; and
    • areas outside New York City decreased by $41.8 million (2.0 percent) to $2.04 billion.

Monday, June 17, 2019

Long Island Business Owner Pleads Guilty (Not Paying Employment Taxes to IRS)



He Failed to Pay Nearly $1 Million in Payroll Tax Withholdings 
(he should have hired SELIG & Associates)

A Long Island business person in the construction industry pleaded guilty today to failing to pay over employment taxes to the Internal Revenue Service (IRS), announced Principal Deputy Assistant Attorney General Richard E. Zuckerman of the Justice Department’s Tax Division. Edward Hansen of Northport, New York, pleaded guilty to one count of willfully failing to collect, truthfully account for, and pay over payroll taxes to the IRS. According to documents filed with the court, Hansen owned and operated steel erection businesses in Suffolk County. From 2008 to 2011, the IRS assessed more than $480,000 in penalties against Hansen for his failure to pay over employment taxes on behalf of several of these businesses. After the last IRS assessment in May 2011, Hansen changed the name of his business to BR-Teck Enterprises Inc., and nominally transferred ownership to another individual. Hansen, however, continued to operate the business and continued to fail to pay over employment taxes. From January 2012 through June 2017, Hansen failed to pay over more than $950,000 in payroll taxes withheld from the wages of BR-Teck’s employees. Hansen faces a maximum sentence of five years in prison for failing to pay over payroll taxes. He also faces a period of supervised release, restitution and monetary penalties. Principal Deputy Assistant Attorney General Zuckerman thanked special agents of IRS-Criminal Investigation, who conducted the investigation, and Tax Division Trial Attorneys, Abigail Burger Chingos and Jeffrey Bender, who are prosecuting the case.

Tuesday, June 11, 2019

Tax Representation before the IRS & NY State (advertisement)



Selig & Associates provides the most aggressive tax representation allowed by law. To schedule a legally privileged consultation with a Federal Tax Practitioner and Attorney please call (212) 974-3435 or contact us online. 

We represent Individuals and Businesses before the IRS and State and specialize in unpaid Income, Sales and Payroll taxes. We negotiate excellent payment plans, compromise tax debts and resolve all civil and criminal tax issues, including suspended New York State Drivers Licenses. 

We provide Restaurant and Business owners with effective Sales and Payroll tax representation, including audits and all Department of Labor and Workers Compensation issues. Missing tax returns can be prepared and filed within 48 hours, guaranteed.   

Our New York City offices are conveniently located and easily accessible by car, train and subway. Same day and emergency appointments are scheduled Monday through Friday.

Tuesday, June 4, 2019

("misclassification of employees as independent contractors")


 
Employer misclassification of employees as independent contractors is a widespread phenomenon in the United States. The Internal Revenue Service estimates that employers have misclassified millions of workers nationally as independent contractors. While some employers misclassify their workers as independent contractors in error, often employers misclassify their employees intentionally in order to reduce labor costs and avoid paying state and federal taxes. The distinction between genuine independent contractors and employees misclassified as independent contractors, while complicated, is a crucial matter. While the definition of misclassification is a function of a complex set of statutes and policies set forth by federal and state agencies, the effect on employees is straightforward. Misclassified employees lose workplace protections, including the right to join a union; face an increased tax burden; receive no overtime pay; and are often ineligible for unemployment insurance and disability compensation. Misclassification also causes federal, state, and local governments to suffer revenue losses as employers circumvent their tax obligations.
 
Defining Independent Contractor
 
An independent contractor provides a good or service to another individual or business, often under the terms of a contract that dictates the work outcome, but the contractor retains control over how they provide the good or service. The independent contractor is not subject to the employer’s control or guidance except as designated in a mutually binding agreement. The contract for a specific job usually describes its expected outcome. Essentially, independent contractors treat their employers more like customers or clients, often have multiple clients, and are self-employed.
 
For some professionals, the line between employee and self-employed independent contractor is often blurred, and employers can classify workers as either. There are several different standards used to determine if an individual is legally an independent contractor. While the intricacies of contracting are too numerous for a comprehensive treatment and the applicability of the test depends on the specific workplace situation, generally, the independent contractor tests employed by the IRS and the Department of Labor (DOL) offer useful guidelines as to who is and who is not an independent contractor.
 
Internal Revenue Service Test
 
The IRS has a stake in identifying the misclassification of employees because it typically results in lost tax revenue. However, the IRS does not have one set of qualifications that it uses to determine the status of “employee” or “independent contractor.” Instead, the IRS looks at a number of factors that help it determine whether an employer has the right to control the details of how the worker(s) performs the services. Generally, if the employer controls the services the worker performs, then the worker is an employee, not an independent contractor. According to the IRS, the facts that provide evidence of the degree of control and independence fall into three categories:
 
Behavioral
 
Does the company control or have the right to control the worker as well as how the worker does his or her job? For example, if a company provides training for the worker, this signals an expectation to follow company guidelines and therefore indicates that the worker is likely an employee.
 
Financial
 
Are the business aspects of the worker’s job controlled by the payer? (These include things like how a worker is paid, whether expenses are reimbursed, who provides tools, supplies, etc.). Only an independent contractor can realize a profit or incur a financial loss from his or her work.
 
Type of Relationship
 
Are there written contracts or employee-type benefits (i.e. pension plan, insurance, vacation pay, etc.)? Will the relationship continue, and is the work a key aspect of the business? 
 
The issue of who has the right to control is often not clear-cut and the tax code does not define “employee.” Businesses must weigh all these factors when determining whether a worker is an employee or independent contractor.
 
The DOL Economic Reality Test
 
The DOL has an interest in ensuring accurate classification because only employees receive Fair Labor Standards Act (FLSA) benefits (Federal minimum wage, overtime pay, etc.). The DOL uses an “economic reality test” to determine who is an employee and, thus, eligible for FLSA benefits, by trying to establish whether the worker is economically dependent on the supposed employer. According to the DOL, “an employee, as distinguished from a person who is engaged in a business of his or her own, is one who, as a matter of economic reality, follows the usual path of an employee and is dependent on the business which he or she serves.”
 
The DOL derives its position from judicial precedent. As the U.S. Supreme Court has not established a single rule or test for determining whether an individual is an independent contractor or an employee, the DOL stresses seven factors the Court has considered significant:
1.    The extent to which the services rendered are an integral part of the principal’s business.
2.    The permanency of the relationship.
3.    The amount of the alleged contractor’s investment in facilities and equipment.
4.    The nature and degree of control by the principal.
5.    The alleged contractor’s opportunities for profit and loss.
6.    The amount of initiative, judgment, or foresight in open market competition with others required for the success of the claimed independent contractor.
7.    The degree of independent business organization and operation.
 
 
These seven factors of the economic reality test aim to assist employers in determining employee or independent contractor status, but in most cases, common sense judgments are sufficient. An employee who only invests time in one enterprise and who sells his or her services to only one “customer,” the employer, is economically dependent upon that work. An independent contractor is in business for him or herself, invests in his or her own equipment and supplies, and has a broad customer base.

Tuesday, May 28, 2019

Insurance Salesman Sentenced on Fraud and Tax Charges




Paul Parker was sentenced to 36 months in prison and ordered to pay $72,805 to the IRS and the Missouri Department of Revenue. Parker pleaded guilty in April to one count of mail fraud and three counts of failure to file a tax return. Parker held an account in the name of American Investors, Inc. for the purported purpose of receiving funds from clients to purchase life insurance annuities. Rather than purchase annuities on his clients’ behalf, Parker spent their money on personal expenses and gambling. In the course of the scheme, Parker also used monies contributed by later clients to fund repayments to prior clients. In total, Parker took in approximately $259,168 through false and fraudulent pretenses, resulting in a loss to investors of approximately $209,168. Parker also admitted to failing to file federal income tax returns for three years from 2010 to 2012.

Restaurant Tax Accountant and Tax Attorney We negotiate excellent installment agreements and provide restaurant owners with effective sales tax and audit representation, including unfiled tax returns and all Department of Labor issues. For a no-obligation consultation call us directly at (212) 974-3435 or contact us Online.

Business Tax Accountant and Tax Attorney We negotiate affordable repayment plans and provide our business clients with effective payroll tax and audit representation, obtaining government contracts with a tax lien, compliance checks, missing tax returns and Workers Compensation audits. For immediate assistance call (212) 974-3435 or contact us Online. 

Thursday, May 23, 2019

Used Car Salesman Sentenced on Tax Charges



James Francis Volin, of Inver Grove Heights, was sentenced to 24 months in prison and ordered to pay $96,599 in restitution. In 2008 Volin agreed to pay nearly $100,000 in outstanding taxes to the IRS. Volin still owed the taxes in 2012 and 2013 when he was operating an unlicensed and illegal used car dealership that generated substantial cash income. Instead of paying the back taxes as agreed, Volin hid the income. Volin did not report the cash income or file tax returns. He put money into cashier’s checks and used bank accounts opened under another person’s name and social security number to avoid detection.

New York City Tax Accountant and Tax Attorney Our New York City offices are conveniently located and easily accessible by car, train and subway. Civil and criminal tax consultations are confidential and legally privileged. Same day and emergency appointments scheduled Monday through Friday. For immediate assistance call (212) 974-3435 or contact us Online. 

Restaurant Tax Accountant and Tax Attorney We negotiate excellent installment agreements and provide restaurant owners with effective sales tax and audit representation, including unfiled tax returns and all Department of Labor issues. For a no-obligation consultation call us directly at (212) 974-3435 or contact us Online.

Business Tax Accountant and Tax Attorney We negotiate affordable repayment plans and provide our business clients with effective payroll tax and audit representation, obtaining government contracts with a tax lien, compliance checks, missing tax returns and Workers Compensation audits. For immediate assistance call (212) 974-3435 or contact us Online. 

Wednesday, May 22, 2019

Former Securities Broker Sentenced For Tax Evasion


Steven Staltare, of New Port Richey, was sentenced to 37 months in prison and ordered restitution of $1,689,248 to the IRS. Staltare pleaded guilty to tax evasion on Dec. 16, 2014. Staltare was a securities broker and evaded paying taxes on income that he had earned during tax years 1999 through 2009, instead, he enjoyed a lavish lifestyle and diverted money from his business for gambling and personal expenses.
Former Nebraska Man Sentenced for Failing to File Tax Returns
On Aug. 25, 2015, in Omaha, Nebraska, Chet Lee West, of Nebo, North Carolina, was sentenced to 51 months in prison, three years of supervised release and ordered to pay $439,515 in restitution. From 2007 through 2009, West earned taxable income of approximately $272,224 while living and working in Omaha. From that income West had a tax due and owing of approximately $52,824. West willfully evaded his personal income taxes by failing to file federal individual income tax returns for tax years 2007 through 2009. After being informed by the IRS that he was required to file federal individual income tax returns, West continued to submit information to his employer in an attempt to avoid the withholding of any employment taxes from his pay, including numerous letters and purported affidavits stating his position that he was not subject to taxation on his income. Between 2007 through 2009, West deposited personal income into bank accounts opened in the names of companies he created in an effort to hide and conceal his income from the IRS. West had not filed federal individual income tax returns since at least the 2000 taxable year.
New York City Tax Accountant and Tax Attorney Our New York City offices are conveniently located and easily accessible by car, train and subway. Civil and criminal tax consultations are confidential and legally privileged. Same day and emergency appointments scheduled Monday through Friday. For immediate assistance call (212) 974-3435 or contact us Online. 

Restaurant Tax Accountant and Tax Attorney We negotiate excellent installment agreements and provide restaurant owners with effective sales tax and audit representation, including unfiled tax returns and all Department of Labor issues. For a no-obligation consultation call us directly at (212) 974-3435 or contact us Online.

Business Tax Accountant and Tax Attorney We negotiate affordable repayment plans and provide our business clients with effective payroll tax and audit representation, obtaining government contracts with a tax lien, compliance checks, missing tax returns and Workers Compensation audits. For immediate assistance call (212) 974-3435 or contact us Online. 

Friday, May 17, 2019

Are FEDERAL INCOME TAXES VIOLATING THE 5th AMENDMENT? (no)


Some individuals and groups say the collection of Federal Income Taxes constitutes a “taking” of property without due process of law, in violation of the Fifth Amendment. Thus, any attempt by the IRS to collect federal income taxes owed by a taxpayer is unconstitutional. 

"Shenanigans"

The Law: The Fifth Amendment to the United States Constitution provides that a person shall not be “deprived of life, liberty, or property, without due process of law . . . .” The United States Supreme Court stated that “it is . . . well settled that [the Fifth Amendment] is not a limitation upon the taxing power conferred upon Congress by the Constitution; in other words, that the Constitution does not conflict with itself by conferring, upon the one hand, a taxing power, and taking the same power away, on the other, by the limitations of the due process clause.”   Brushaber v. Union Pacific R.R., 240 U.S. 1, 24 (1916).  Further, the Supreme Court has upheld the constitutionality of the summary administrative procedures contained in the Internal Revenue Code against due process challenges on the basis that a post-collection remedy (e.g., a tax refund suit) exists and is sufficient to satisfy the requirements of constitutional due process.  Phillips v. Commissioner, 283 U.S. 589, 595-97 (1931).

The Internal Revenue Code provides methods to ensure due process to taxpayers: (1) the “refund method,” set forth in section 7422(e) and 28 U.S.C. §§ 1341 and 1346(a), in which a taxpayer must pay the full amount of the tax and then sue for a refund in a federal district court or in the United States Court of Federal Claims; and (2) the “deficiency method,” set forth in section 6213(a), in which a taxpayer may, without paying the contested tax, petition the United States Tax Court to redetermine a tax deficiency asserted by the IRS.  Courts have found that both methods provide constitutional due process.

In  Rev. Rul. 2005-19 2005-1 C.B. 819 and in Notice 2010-33, 2010-17 I.R.B. 609, the IRS discussed this frivolous argument in more detail and warned taxpayers of the consequences of attempting to pursue a claim on these grounds.

For a discussion of frivolous tax arguments made in collection due process cases arising under sections 6320 and 6330, see Section II of this outline.

Relevant Case Law:Flora v. United States, 362 U.S. 145, 175 (1960) – the Supreme Court held that a taxpayer must pay the full tax assessment before being able to file a refund suit in district court, noting that a person has the right to appeal an assessment to the Tax Court “without paying a cent.”

Taliaferro v. Freeman, 595 F.App’x 961, 962-63 (11th Cir. 2014) - ordering sanctions against the taxpayer up to and including double the government’s costs, the 11th Circuit held that the taxpayer’s contention that IRS levies violate the Fifth Amendment right to due process was “simply without merit” and did not even warrant discussion.

Schiff v. United States, 919 F.2d 830 (2d Cir. 1990) – the 2nd Circuit rejected a due process claim of a taxpayer who chose not to avail himself of the opportunity to appeal a deficiency notice to the Tax Court.

Obrien v. Green, 114 A.F.T.R.2d (RIA) 2014-5613 (E.D. Va. 2014) – the court rejected as frivolous the taxpayer’s claim that an IRS levy violated the Fifth Amendment.
Other Cases: Lund v. Chase Bank, 114 A.F.T.R.2d (RIA) 2014-5613 (D. Or. 2014); Rivas v. Commissioner, T.C. Memo. 2016-158, 112 T.C.M. (CCH) 247 (2016), appeal dismissed sub nom. Rivas v. Commissioner, No. 16-16365-C, 2017 WL 4842564 (11th Cir. Aug. 15, 2017).

New York City Tax Accountant and Tax Attorney Our New York City offices are conveniently located and easily accessible by car, train and subway. *Our civil and criminal tax consultations are confidential and legally privileged. Same day and emergency appointments may be scheduled Monday through Friday. For immediate assistance call (212) 974-3435 or contact us Online. 

Restaurant Tax Accountant and Tax Attorney We negotiate excellent installment agreements and provide restaurant owners with effective sales tax and audit representation, including unfiled tax returns and all Department of Labor issues. For a no-obligation consultation call us directly at (212) 974-3435 or contact us Online.

Business Tax Accountant and Tax Attorney We negotiate affordable repayment plans and provide our business clients with effective payroll tax and audit representation, obtaining government contracts with a tax lien, compliance checks, missing tax returns and Workers Compensation audits. For immediate assistance call (212) 974-3435 or contact us Online. 

Tax Accountant and Attorney Serious tax problems deserve serious attention. We provide the most aggressive tax representation allowed by law. We meet with each and every client personally. We specialize in unpaid income, sales and payroll taxes. We settle contested tax audits; negotiate excellent payment plans, compromise tax debts and resolve all civil and criminal tax issues, including suspended NYS Drivers Licenses, innocent spouse relief and separation of liability. For immediate assistance call (212) 974-3435 or contact us Online. 

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