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The Doctrine of Constructive Receipt
Under the doctrine of constructive receipt, a cash-basis taxpayer who has an unrestricted right to receive income is treated as though they actually received the income–even if they did not.  Thus, even when a taxpayer

Overview of IRS Notice CP518.
The IRS Collection Procedure Notice 518 (CP518) is a notification that the IRS believes a taxpayer—either a business or an individual—has failed to file a required return, either as of the initial deadline for filing

The Foreign Agents Registration Act was put under the microscope recently during a hearing before the House Judiciary Subcommittee on the Constitution, Civil Rights, and Civil Liberties. As explained in a previous post, FARA requires certain individuals and entities

The IRS sends a CP504 Notice when a taxpayer has failed to pay a balance owed.  The CP504 Notice is a Notice of Intent to Levy issued pursuant to Section 6331(d) of the Internal Revenue Code.  If a taxpayer fails to

Through nearly 20 years of law practice–15 of which have been focused on the representation of tax-exempt organizations–this writer has been involved in numerous seemingly simple–and some cutting edge–applications for exemption from Texas property taxes for religious organizations. In most