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Reverse Eggshell Audits: The IRS Knows More Than You Think

October 20, 2025 Virtuoso No Comments
Many taxpayers believe an IRS audit is just a civil matter. But in some cases, by the time the audit begins, damaging information is already in the hands of the government. That’s what makes a reverse eggshell audit far more dangerous than it appears on the surface. What Is an…
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Late Payroll Tax Deposits? Here’s How the IRS Penalties Add Up

October 10, 2025 Virtuoso No Comments
When it comes to payroll taxes, the IRS expects precision. Employers are required to withhold federal income tax, Social Security, and Medicare from employee wages. You must also deposit those funds on time, in the correct amount, and through the proper channels. When deposits are late or missed, the IRS…
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What to Do When an IRS Revenue Officer Shows Up

September 30, 2025 Virtuoso No Comments
When the IRS assigns a Revenue Officer to your case, it’s a sign your tax situation has moved beyond routine notices. It’s a serious problem, but you can get in front of it with the right professional help. What Does a Revenue Officer Do? A Revenue Officer is a highly…
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IRS Statutes of Limitations: How the Clock Can Pause on Your Tax Debt

September 17, 2025 Virtuoso No Comments
The IRS generally has strict statutes of limitations for assessment (usually three years from filing) and collection (generally 10 years from assessment). Still, certain events can toll (pause) or extend those timeframes. The Basics: Assessment vs. Collection An “assessment period” and “collection period” aren’t the same thing, but they often…
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Representing Clients in Tax Court: When and Why Litigation Matters

September 1, 2025 legalpodcastnetwork No Comments
When does a tax dispute escalate to U.S. Tax Court? Attorney Juda Gabaie explained that tax court becomes necessary when the IRS issues a Notice of Deficiency or a Notice of Determination. A Notice of Deficiency is essentially the government’s statement that a taxpayer owes a specific amount, giving the…
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Tax Liens and Levies: How to Protect Assets from the IRS

September 1, 2025 legalpodcastnetwork No Comments
What is the difference between a tax lien and a tax levy? Attorney Juda Gabaie explained that tax liens and tax levies are two of the most common and powerful IRS enforcement actions, but they operate very differently. A tax lien is the government’s legal claim against a taxpayer’s property…
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Trust Fund Recovery Penalty: Avoiding Personal Liability in California

August 24, 2025 legalpodcastnetwork No Comments
The Trust Fund Recovery Penalty (TFRP) represents one of the IRS’s most severe enforcement tools, targeting individuals responsible for unpaid payroll and sales taxes. This episode of The Power of Tax Defense Attorneys: Tax Corner with Juda Gabaie examines the TFRP’s implications for California business owners, detailing the criteria for…
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Piercing the Corporate Veil: When the IRS Looks Past the Entity

August 20, 2025 Virtuoso No Comments
Forming a corporation or LLC can offer powerful asset protection, allowing business owners to be separate from their businesses for tax reasons. However, the IRS can shatter this protection when it “pierces the corporate veil,” or treats the business and its owners as one entity in tax enforcement actions. What…
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IRS Form 668-A: How the Government Can Seize Funds Owed to You

August 10, 2025 Virtuoso No Comments
When the IRS believes you owe back taxes, it could send Form 668-A. It’s not a form for you, however; it’s a legal notice sent to third parties to seize money owed to you. This one-time levy can freeze your assets fast. Learn how it works and what you can…
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