Published Articles

The attorneys at Segal, Cohen & Landis have written articles and legal briefs on a wide range of topics pertaining to tax controversy which have been published in reputable outlets such as Thompson Reuters, Haute Lawyer along with local and national news platforms. They have also served as legal authority in several court cases. Some of those articles are reproduced here for your reference.

What To Do When You Disagree with an IRS Audit

What To Do When You Disagree with an IRS Audit


Typically, an IRS examination of one’s tax return will result in the assessment of additional taxes, penalties, and interest. Most taxpayers disagree with their auditor’s findings and want an opportunity to challenge their new tax bill. Thankfully, the auditor’s report of examination changes which contains proposed adjustments to your tax return is not necessarily the final arbiter on how much you will have to pay. The IRS created an Office of Appeals which is separate and independent from its other departments with a view to provide an impartial forum for resolution of tax controversies without resort to litigation. When an…
Are You at Risk of an IRS Audit and How Far Back Can the IRS Go?

Are You at Risk of an IRS Audit and How Far Back Can the IRS Go?


The IRS conducts hundreds of thousands of audits a year, typically resulting in the taxpayer owing significantly more tax.   Most people shudder at the thought of having their tax return examined by an auditor and worry that they might not have sufficient records to defend it.  This article explores what might trigger an IRS audit and how far back the IRS can audit you. IRS Audit Selection The IRS audit process involves a review of the individual and/or business tax return(s) and supporting documents to confirm that the information has been reported correctly and that the tax due is accurate.…
What is the Difference between the IRS Fresh Start Program and an Offer in Compromise?

What is the Difference between the IRS Fresh Start Program and an Offer in Compromise?


What is the Difference between the IRS Fresh Start Program and an Offer in Compromise? You may have seen advertisements about tax relief available through the IRS Fresh Start program for taxpayers who qualify.  You might have also read articles about paying less than you owe via the IRS Offer in Compromise.  These programs often get confused and some of the articles and advertisements referencing them are a little misleading.  We’re going to clear it up for you now. In a nutshell, the Fresh Start program consists of changes to IRS collection policy that expand existing IRS resolution programs with…
passport restrictions

IRS Delinquencies & Passport Restrictions: What You Need to Know


You may be surprised to learn that having an unpaid tax bill with the federal government could potentially hamper your ability to travel or live abroad.  Each year hundreds of taxpayers with IRS delinquencies encounter restrictions on their United States Passports preventing them from traveling to and from most international destinations.  Sometimes the unsuspecting taxpayer doesn’t realize there is an issue with his passport until he is at the airport! Are you wondering what kind of outstanding tax liability gets you in trouble with the State Department and how to avoid cumbersome passport restrictions?  Keep reading to learn what qualifies…
Segal Cohen & Landis CALIFORNIA

Residency And Taxing In California


Residency And Taxing In California: THE UNCERTAIN CERTAINTY OF THE LAW by Samuel Landis, LL.M The State of California taxes individuals based upon their residency in the State and, otherwise, on their income derived from the State. A full-time resident of California will be taxed upon all of his income, regardless of source, during a tax year (Revenue & Taxation Code § 17041(a)); a part-year resident of the State will be taxed on all of his income earned during that period of the tax year when he was residing in the State and, otherwise, taxed on income derived from a…
Wage Garnishment

Wage Garnishments Featured Article


Introduction Every individual in the United States is expected to pay their taxes so that government can provide various public services and benefits. If one neglects to pay their taxes, serious consequences ensue. In spite of this generally well-known idea, several individuals still refuse to pay their taxes each year. After several warnings to these individuals, the government will take action to recover unpaid taxes. One thing that the government will do is issue a wage garnishment. A wage garnishment is a serious matter and must be taken care of quickly in order to avoid further penalties. Basically, a wage…