Sanjeev ghai income tax
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This document contains biographies of three faculty members teaching a federal income tax law course, including their educational backgrounds and professional experiences. It also outlines techniques for resolving tax issues with the IRS, such as requesting a meeting with all parties involved, including any commercial tax preparers, and clearly communicating the taxpayer's position on any IRS notices within the timeframes required.
Sanjeev ghai income tax
- 1. FEDERAL INCOME TAX LAW COURSE DESKBOOK
- 2. FACULTY BIOGRAPHIES • LIEUTENANT COLONEL JANET H. FENTON, JA, Deputy, Legal Assistance Policy • Division. B.A., Idaho State University, 1983; J.D., Pepperdine University School of Law, 1986; • 114th Judge Advocate Officer Basic Course, 1987; Combined Arms and Services Staff School, • 1995; LL.M., 44th Judge Advocate Officer Graduate Course, 1996; United States Army • Command and General Staff College, 1999; LL.M. (Taxation), University of Washington School • of Law, 2001. Legal Assistance Attorney, Fort Shafter, Hawaii, 1987-Oct 1988; Special • Assistant U.S. Attorney, Fort Shafter, Hawaii, Oct 1988- Oct 1989; Defense Counsel, Schofield • Barracks, Hawaii, Oct 1989- Dec 1990; Chief, Legal Assistance, Fort Ord, California, Dec 1990- • Aug 1991; Chief, Military Justice, Fort Sam Houston, Texas, Aug 1991- 1993; 5th Recruiting • Brigade Judge Advocate, Fort Sam Houston, Texas, 1993-1995; Professor, Legal Assistance • Branch, Administrative and Civil Law Department, The Judge Advocate General’s School, • Charlottesville, Virginia, 1996-1999; Chief, Claims, Fort Lewis, Washington, Jun 1999-Jan • 2000; Chief, Military Justice, Fort Lewis, Washington, Feb 2000- Aug 2000; Deputy, Legal • Assistance Policy Division, Washington D.C., 2001-2003; Executive Director, Armed Forces • Tax Council, Washington, D.C., 2003-2006. Member of the Bars of Hawaii, Texas, Washington, • 9th Circuit Court of Appeals, and the United States Court of Appeals for the Armed Forces.
- 3. • LIEUTENANT COLONEL SAMUEL W. KAN, JA, Professor and Vice Chair, • Administrative and Civil Law Department. B.S., United States Military Academy, 1994; J.D., • The University of Texas School of Law, 2000; LL.M. (Military Law), 54th Judge Advocate • Graduate Course, 2006; LL.M. (Taxation, with Certificate in Estate Planning), Georgetown • University Law Center, 2009. Air Assault, 1992; Military Police Officer Basic Course, • Protective Services, and Master Fitness, 1994; 153rd Judge Advocate Basic Course, 2000; • Combined Arms and Services Staff School, 2002; Intermediate Level Education, 2008. Platoon • Leader and Executive Officer, 401st Military Police Company, 720th Military Police Battalion, • 89th Military Police Brigade, Fort Hood, Texas, with a deployment to Panama, 1995-1997; • Administrative Law Attorney and Chief of Administrative Law, 2nd Infantry Division, South • Korea, 2001-2002; Trial Counsel, Chief of Claims, and Chief of Legal Assistance, 25th Infantry • Division, Schofield Barracks, Hawaii, with a deployment to Afghanistan with CJTF-76, 2002- • 2005; Senior Defense Counsel, Fort Stewart, Georgia, 2006-2008. Member of the Bars of Texas, • the United States Supreme Court, and the United States Court of Federal Claims
- 4. • LIEUTENANT COLONEL DON F. SVENDSEN, JR., is an Air Force Reserve attorney • attached to the Air Force Judge Advocate School, Maxwell, Alabama. Upon graduation from the • College of William and Mary in 1990, Lieutenant Colonel Svendsen was commissioned an active • duty second lieutenant in the US Army field artillery. He served as a fire support officer with the • 1/72 Armored Tank Battalion, 2d Infantry Division, Camp Casey, Korea, transferred to the • Finance Corps and continued to serve with various increasingly responsible positions at Fort • Belvoir, Virginia, the Army Staff at the Pentagon, and finally with the Eighth Quadrennial • Review of Military Compensation with the Office of the Secretary of Defense. Upon leaving • active duty, Lieutenant Colonel Svendsen worked at the accounting firm, Coopers & Lybrand • LLP (later PricewaterhouseCoopers LLP) as a tax manager, at a small law firm specializing in • estate tax planning, and as the Chief of Enforcement for the Internal Revenue Service Office of • Professional Responsibility. Lieutenant Colonel Svendsen is a graduate of the George • Washington University law school, the Air Command and Staff College, and the Air War • College. In his civilian capacity, Lieutenant Colonel Svendsen currently serves as the Assistant • Director for Military Compensation in the Office of the Secretary of Defense.
- 5. RESOLUTION TECHNIQUES • A. Talking to all of the players. • 1. Taxpayer prepared return. You’ll save a lot of time and energy if you • meet with the taxpayer that actually prepared the return. The spouse that • keeps the household records or the spouse that was available for the • appointment or the child whose parent prepared the return are all going to • balk at the significant questions you pose. Hours can be wasted trying to • calculate basis or useful life where the preparer has the information at their • fingertips. • 2. Tax Center prepared return. A call to the Tax Center might prove • rewarding. While Tax Center personnel tend to be transient, offices often • retain previous years returns. Additionally, someone at the Tax Center • may be attempting to assist or contact the taxpayer on the issues in • dispute. • 3. Commercially prepared returns. The taxpayer may have paid for some • sort of audit assistance or penalty and interest insurance. Most contractual • provisions require the taxpayer to promptly notify the preparer of any IRS • notice
- 6. REQUESTING RELIEF. • A. IRS notices commonly ask the taxpayer to characterize his position with regard to the issue. • • 1. Fully agree with the notice. There is no issue in controversy. The • taxpayers may wish to have the interest abated. The IRS Restructuring • and Reform Act of 1998 requires the IRS to notify taxpayers of proposed • discrepancies within 18 months of the original filing date in order to • charge interest. Additionally, the Tax Reform Act of 1986 allows the IRS • to reduce or remove interest attributable to errors or delays made by the • IRS in the performance of ministerial acts. • 2. Partially agree with the notice. The taxpayers wish to have the IRS reduce • any taxes attributed to the incorrect changes made by the IRS. Taxpayers • will substantiate the correct entries and ask the IRS to recompute taxes, • penalties and interest.
- 7. • 3. Wholly disagree with the notice. Taxpayers will substantiate the entries • and computations on the return and ask the IRS to confirm the original • taxes due or refund requested. • B. Regardless of the position the taxpayers take on the notice, the reply to any notice • should clearly state the name and address of the taxpayers, the tax year in • question, the tax form originally filed, the notice to which the reply pertains, and • any client authorization involved. Enclose the reply in the bar coded envelope • provided by the IRS. The IRS Service Center must hand sort other envelopes and • this will increase the processing time, at best. At worst the plain envelope will be • routed to an incorrect office