In Vincent C. Hamilton and Stephanie Hamilton v. Comm’r,
T.C. Memo 2018-62, filed May 8, 2018, the Tax Court explores a common
exception to inclusion of discharge of indebtedness in gross income.
Gross income generally includes discharge of indebtedness – I.R.C.
section 61(a)(12). Section 108(a)(1)(B) excludes income from the
discharge of indebtedness from gross income if the discharge occurs when
the taxpayer is insolvent. Insolvency is measured by comparing the
excess of the taxpayer’s liabilities over the fair market value of the
taxpayer’s assets immediately before discharge. Taxpayers borrowed money
in order to finance their son’s education. The husband ultimately
injured his back and became permanently disabled. The student loan
provider discharged over $158,000 in student loan debt. Husband then
exhibited poor money management skills and his wife took over their
finances. To protect their assets, she transferred $323,000 into their
son’s savings account. She had the password and permission from her son
to transfer money. She did this regularly during the year at issue to
pay bills from her joint account with her husband. When filing the
return, their accountant advised they were insolvent and claimed as much
on the return. He had not included the value of the savings account in
the son’s name. In this case, the sole issue is whether or not a bank
account of taxpayers’ son should be included in their asset calculation.
In this case, the taxpayers failed to prove that their son was not
their nominee because they continued to enjoy the benefits of the funds
they transferred to their son’s savings account. There was no evidence
that the son paid any consideration for the funds transferred to his
savings account by the taxpayers. As such, the funds were included as
assets of the taxpayers, and the taxpayers were no longer insolvent.
In Connie L. Minton a.k.a. Connie L. Keeney v. Comm’r, T.C. Memo 2018-15, filed February 5, 2018, the Tax Court was asked to review an IRS Appeals’ decision denying innocent spouse relief based on equitable relief. In this case, taxpayer made application for relief after divorce. The return in question reflected income from a 401(k) withdrawal taxpayer instituted at the request of her former spouse – for the purpose of investing in a business venture that failed. Additionally, the spouse’s income from his business, along with a small amount of interest income was reported on the return. The Appeals officer indicated that the taxpayer’s request for relief failed because the tax was attributed to her income. Thus, it did not meet the threshold condition for relief. The Tax Court reviewed this decision and discussed the exceptions to the attribution rule. Those exceptions include: a) attribution due solely to the operation of community property law, b) nominal ownership, c) misappropriation of funds, d) abuse before the return was filed that affects the requesting spouse’s ability to challenge the treatment of items on the return or question payment of any balance due, and e) fraud committed by the nonrequesting spouse that is the reason for the erroneous item. Ultimately, the Court indicated that the taxpayer did not meet any of the exceptions and failed the threshold conditions as to her 401(k) withdrawal. The Tax Court, however, disagreed with Appeals in that they concluded the liability attributed to the nonrequesting spouse’s business income should not be attributed to the taxpayer because her involvement in the business was nominal only. This is a good discussion of some exceptions to the income attribution rule, not regularly reviewed by the Court.
If
a taxpayer has “seriously delinquent tax debt,” the IRS will certify
that debt to the State Department for action. The State Department will
generally not issue a passport to a taxpayer after receiving
certification from the IRS. Further, the State Department may revoke a
taxpayer’s passport on certification from the IRS. “Seriously delinquent
tax debt” is defined as a tax debt currently in excess of $51,000 (this
is inflation adjusted), for which a notice of federal tax lien has been
issued and all administrative remedies under I.R.C. section 6320 have
lapsed or been exhausted, or a levy has been issued. Some tax debts are
not included, even if they meet the above criteria. This includes tax
debt that is being paid timely on an IRS approved installment agreement,
is being paid timely with an accepted Offer in Compromise, is pending a
timely requested Collection Due Process hearing regarding a levy, or
for which collection is suspended because of an application for innocent
spouse relief. Additionally, a passport won’t be at risk under the
program if the taxpayer is in bankruptcy, identified by the IRS as a
victim of identity theft, if the taxpayer’s account is in currently not
collectible, if the taxpayer resides in a federally declared disaster
area, if the taxpayer has a pending request for an installment
agreement, if the taxpayer has a pending Offer in Compromise, or if the
taxpayer has an IRS accepted adjustment that will satisfy the debt in
full. Before denying a passport, the State Department will hold the
application for 90 days to allow the taxpayer to resolve any erroneous
certification issues, make a full payment of the tax debt, or enter a
payment arrangement with the IRS.
This is a hard fought case on a narrow issue that ultimately went in favor of the IRS. The Tax Court in Scott T. Blackburn v. Comm’r,
150 T.C. No. 9, filed April 9, 2018, was asked to review the
verification of compliance rule of I.R.C. section 6751(b), as required
by sections 6330(c)(1) and (3)(A). The Appeals officer must “obtain
verification from the Secretary that the requirements of any applicable
law or administrative procedure have been met.” Sec. 6330(c)(1). The
Petitioner did not argue or contest the liability issue relating to
assessment of the Trust Fund Recovery Penalty against him. The Revenue
Officer in this instance has recommended assessment and said assessment
was approved by the Revenue Officer’s manager using Form 4183. The name
of the manager was listed on the form, but no signature was present. The
taxpayer argued that in creating section 6751(b), Congress could not
have meant to require a meaningless, supervisory “rubber stamped”
signature. Petitioner asked the IRS many times to provide some evidence
that the supervisor’s review was meaningful. Petitioner relies on the
Internal Revenue Manual to suggest an argument that the signature of a
supervisor in support of a penalty is not in itself a sufficient showing
to comply with section 6751(b). The Court indicated that caselaw review
applying these code sections has only required the officer to review
the administrative steps taken before assessment of the underlying
liability. To impose the requirement of a substantive review on the
officer would allow the taxpayer to avoid the limitations of pursuing
the underlying liability in a review under section 6330 and apply a
level of detail in the verification process that has never been
previously required, the Court explained.
In Daniel Sadek v. Comm’r,
T.C. Memo 2018-174, Filed October 16, 2018, the Tax Court takes up the
issue of what is deemed to be an appropriate address for the issuance of
a notice of deficiency. The rule is set out in I.R.C. section
6212(b)(1): a deficiency notice sent to the taxpayer’s last known
address, shall be sufficient. Treasury Regulation section 301.6212-2(a)
elaborates: “A taxpayer’s last known address is the address that appears
on the taxpayer’s most recently filed and properly processed Federal
tax return, unless the IRS is given clear and concise notification of a
different address.” In this case, taxpayer’s most recently filed tax
return was for 2005, which was filed October 19, 2009. The IRS issued a
notice of deficiency for 2005 and 2006 in excess of $25 million dollars,
to his address in both California and Nevada. This notice was issued
August 25, 2011. Petitioner filed his petition with the Tax Court on
January 4, 2017. From September 2010 through May 2014 Petitioner lived
in Beirut, Lebanon. Despite the seemingly straightforward notification
provision, Petitioner made a couple of arguments that the IRS should
have known where he was living. First, the Petitioner argued that the
IRS had used his bankruptcy filings to determine that he also had a home
in Nevada. The Petitioner argued that the IRS should have known better
as the automatic stay had been lifted during the bankruptcy proceedings
to allow both lenders to foreclose – thus he no longer could have lived
there. There was no evidence the foreclosure actually took place, and no
other address was referenced in any bankruptcy filing. Next, while
residing in Beirut, Lebanon, the Petitioner was the subject of an
investigation by the FBI relating to his former mortgage business.
Petitioner had several communications from Beirut with the FBI during
this time. The testifying agent indicated that the FBI never had
Petitioner’s address, and even if they did, they would not share the
details of an ongoing criminal investigation with non-law enforcement
agents of the IRS. The Court declined to “impute to the [IRS] the
knowledge of the entire Federal Government.” That simply is not the
requirement of the statute referenced above. The Court explained that
even if the FBI had the address, and even if the Petitioner had provided
the State Department with an address while in Lebanon, “change of
address information that a taxpayer provides to another government
agency, is not clear and concise notification of a different address,”
per Treasury regulation section 301.6212-2(b)(1). Petitioner’s petition
was deemed untimely and the deficiency stood.
In Hudson v. Comm’r T.C.
Summary Opinion 2017-7, filed February 8, 2017, the Tax Court granted
equitable relief from joint and several liability under section
6015(f). It is a rare case that the IRS grants relief to a taxpayer
that requests innocent spouse relief, unless that individual is legally
separated or divorced from the jointly liable taxpayer. The taxpayer and
her husband remained legally married, but were essentially estranged.
Petitioner remained in the marriage because she “regards the vow of
marriage as sacrosanct and does not believe in divorce.” The liability
reported on the face of the return was largely from the early withdrawal
penalty associated with Petitioner’s husband taking a distribution from
his retirement account to finance the purchase of a piece of
residential real estate – in his name alone. Though petitioner resided
at this residence, the Tax Court did not believe she enjoyed a lavish
lifestyle. Petitioner held a bachelors degree and, while she was out of
the workplace caring for their children during the year at issue, she
later became employed in her field. At the time of filing the Petition
in the Tax Court, she was unemployed and struggled with reasonable
living expenses. The Court could not provide “streamlined” relief
because the Petitioner remained married. That triggered a facts and
circumstances analysis where economic hardship and lack of significant
benefit factored heavily into the Court’s grant of liability relief.
IRS Announces 2016 Inflation Adjustments on Several Tax Benefits and Retirement Adjustments
The IRS recently announced annual
inflation adjustments for several tax provisions, which will apply to
the 2016 tax year. Some of the affected provisions include: income tax
rate schedules, the estate tax exemption, long-term care adjustments,
and retirement adjustments. Below is a summary of those adjustments.
Tax Rates. Beginning in the 2016 tax year, the following tax rates will apply:
If the Taxable Income Is:
The Tax for Married Individuals Filing Jointly is:
Less than or equal to $18,550
10% of the taxable income
Over $18,550 but not over $75,300
$1,855 plus 15% of the excess over $18,550
Over $75,300 but not over $151, 900
$10,367.50 plus 25% of the excess over $75,300
Over $151,900 but not over $231,450
$29,517.50 plus 28% of the excess over $151,900
Over $231,450 but not over $413,350
$51,791.50 plus 33% of the excess over $231,450
Over $413,350 but not over $466,950
$111,818.50 plus 35% of the excess over $413,350
Over $466,950
$130,578.50 plus 39.6% of the excess over $466,950
If the Taxable Income Is:
The Tax for Heads of Households is:
Not over $13,250
10% of the taxable income
Over $13,250 but not over $50,400
$1,325 plus 15% of the excess over $13,250
Over $50,400 but not over $130,150
$6,897.50 plus 25% of the excess over $50,400
Over $130,150 but not over $210,800
$26,835 plus 28% of the excess over $130,150
Over $210,800 but not over $413,350
$49,417 plus 33% of the excess over $210,800
Over $413,350 but not over $441,000
$116,258.50 plus 35% of the excess over $413,350
Over $441,000
$125,936 plus 39.6% of the excess over $441,000
If the Taxable Income Is:
The Tax for Unmarried Individuals is:
Not over $9,275
10% of the taxable income
Over $9,275 but not over $37,650
$927.50 plus 15% of the excess over $9,275
Over $37,650 but not over $91,150
$5,183.75 plus 25% of the excess over $37,650
Over $91,150 but not over $190,150
$18,558.75 plus 28% of the excess over $91,150
Over $190,150 but not over $413,350
$46,278.75 plus 33% of the excess over $190,150
Over $413,350 but not over $415,050
$119,934.75 plus 35% of the excess over $413,350
Over $415,050
$120,529.75 plus 39.9% of the excess over $415,050
If the Taxable Income Is:
The Tax for Married Individuals Filing Separate Returns is:
Not over $9,275
10% of the taxable income
Over $9,275 but not over $37,650
$927.50 plus 15% of the excess over $9,275
Over $37,650 but not over $75,950
$5,183.75 plus 25% of the excess over $37,650
Over $75,950 but not over $115,725
$14,758.75 plus 28% of the excess over $75,950
Over $115,725 but not over $206,675
$25,895.75 plus 33% of the excess over $115,725
Over $206,675 but not over $233,475
$55,909.25 plus 35% of the excess over $206,675
Over $233,475
$65,289.25 plus 39.6% of the excess over $233,475
If the Taxable Income Is:
The Tax for Estates and Trusts is:
Not over $2,550
15% of the taxable income
Over $2,550 but not over $5,950
$382.50 plus 25% of the excess over $2,550
Over $5,950 but not over $9,050
$1,232.50 plus 28% of the excess over $5,950
Over $9,050 but not over $12,400
$2,100.50 plus 33% of the excess over $9,050
Over $12,400
$3,206.00 plus 39.6% of the excess over $12,400
Estate Tax Exemption.
The Estate Tax is a tax imposed on the transfer of property at a
person’s death, for any portion of the decedent’s gross estate that
exceeds the Federal Estate Tax Exemption. This year the estate tax
exclusion has increased from a total of $5,430,000 to $5,450,000. This
means that decedents who die in 2016 have an estate tax exclusion that
has increased by $20,000 from the previous year.
Long-term Care. Deductions for Long Term Care Insurance Premiums have increased slightly from 2015. The 2016 deductible limits under §213(d)(10) for eligible long-term care premiums are as follows:
Attained Age Before Close of Taxable Year
Limitation on Premiums
40 or less
$390
More than 40 but not more than 50
$730
More than 50 but not more than 60
$1,460
More than 60 but not more than 70
$3,900
More than 70
$4,870
Retirement Adjustments.
The elective deferral (contribution) limit for employees who
participate in 401(k), 403(b), most 457 plans, and the government’s
Thrift Savings Plan remains unchanged at $18,000. In addition, if you
are 50 or over you can contribute an additional $6,000 as a catch-up
contribution. The limit on annual contributions to IRA accounts remains
unchanged at $5,500 with the catch-up contribution limit remaining
$1,000.
The deduction for taxpayers making
contributions to traditional IRA accounts is phased out gradually
starting at an Adjusted Gross Income (AGI) of $61,000 for single
taxpayers and heads of households, $98,000 for married couples filing
jointly (when the spouse who makes the IRA contribution is covered by a
workplace retirement plan). These amounts are unchanged in 2016. The
phase out moves from a starting point of $183,000 to $184,000 for an IRA
contributor not covered by a workplace retirement plan but who is
married to someone who is covered.
The deduction for taxpayers making
contributions to a Roth IRA is phased out gradually starting at an AGI
of $184,000 for married couples filing jointly and $117,000 for singles
and heads of households.
Lastly, the AGI limit for the saver’s
credit (retirement savings contribution credit) for low and moderate
income workers has also increased slightly for 2016. The credit is now
$61,500 for married couples filing jointly, $46,125 for heads of
household, and $30,750 for singles and married couples who file
separately.
If you have any questions about how these
adjustments might affect your tax situation, please feel free to contact
our office for further assistance.
The National Taxpayer Advocate has reported in its Fiscal Year 2016 Objectives report to Congress that a proposal by the IRS to expand collection efforts against retirement plans of federal employees “infringes on taxpayers’ rights to a fair and just tax system.” Federal employees have the ability to participate in the Thrift Savings Plan (TSP), which is similar to a private sector 401(k) plan in that employee savings are tax deferred and qualify for some level of employer, (in this case the federal government), matching.
Taxpayers, including federal government employees, who owe taxes are subject to IRS levy on their property and rights to property. This power extends to retirement accounts, including the TSP. However, given the importance of retirement savings to an individual’s welfare during old age, the IRS has historically regarded a levy on retirement funds as a special case that requires additional scrutiny and a manager’s approval.
Essentially, before a field Revenue Officer can levy a retirement benefit, the agent would determine what property is available to levy – both retirement and non-retirement, determine if the taxpayer has acted in a flagrant manner, and finally determine if the retirement funds are required for necessary living expenses. There are distinct problems with these factors, but that has been partially mitigated by other requirements prior to issuance of the levy. The field Revenue Officer must either secure the signature of the Area Director of Field collections, or secure a manager’s approval.
In order to obtain a collection manager’s approval in this instance, the field Revenue Officer is required to draft a detailed memo that sets out a summary of all information provided to the agent by the taxpayer, whether the taxpayer has exhibited any flagrant behavior, and more importantly, other collection alternatives that have been considered and rejected. In other words, the retirement account falls into a secondary level of collection after the field Revenue Officer reviews other property or income to levy.
Recent activity at the IRS has created a pilot program to levy TSP accounts. Most importantly, and of greatest concern, this program will be administered by ACS employees. ACS is the Automated Collection System unit. When a taxpayer’s account is in ACS, it is not assigned to a single employee for collection, rather, there are various employees in functions and units that work on similar matters. These employees do not receive the same level of financial analysis training as a field Revenue Officer.
In addition to the reduced training received by ACS employees, the pilot program calls for ACS employees to document any information that a retirement is impending and that the taxpayer will be relying on funds from the TSP for necessary living expenses. This lacks any analysis regarding other property the taxpayer may have that would be available to collect from, or if the taxpayer acted in a flagrant manner, all requirements of a field Revenue Officer.
Finally, the pilot program requires managerial approval prior to levy on retirement accounts – but that is a requirement of many collection actions by ACS employees – hardly elevating these situation to a special case status. What is not referenced is the required memo to the manager detailing information provided by the taxpayer and collection alternatives considered and rejected before proposing levy to the retirement account – all requirements of the field Revenue Officer.
In summary, the IRS is targeting one type of retirement account, the TSP, for increased collection activity, over all others. ACS does not have the ability to levy any other retirement accounts at this time. The National Taxpayer Advocate believes that this pilot program undermines both taxpayer rights and retirement security policy. As such, the National Taxpayer Advocate is going to continue to push the IRS to abandon the Thrift Savings Plan levy pilot program If the IRS adopts the program, the National Taxpayer Advocate is prepared to accept all TSP levy cases coming from ACS. Taxpayers should take advantage of this opportunity to protect their retirement income. Additionally, where possible, taxpayers should seek assistance from the Appeals division in order to entertain collection alternatives through Appeals’ Collection Due Process hearing procedures. Feel free to contact Caraker Law Firm, P.C. with any questions you may have.
IRS institutes Early Interaction Initiative for Employment Tax matters
It
is expected that the IRS will be instituting swifter action against
employers that are falling behind on their Federal Tax Deposits (FTD’s)
for employment taxes. Those taxpayers who have had interaction with a
field Revenue Officer are likely hearing from those Revenue Officers
more quickly if they fall behind on their required deposits. However,
the IRS announced in December 2015 that it is instituting efforts to
identify employers who appear to be falling behind on their tax payments
– apparently even before their employment tax return is being filed.
The IRS has indicated that
their identification efforts will result in letters, automated phone
messages, and other communications which could include a visit from a
field Revenue Officer. The IRS has indicated that this effort will
reduce the likelihood of the problem becoming uncontrollable. Many
taxpayers simply do not realize how steep the penalties can be for
failure to properly make tax deposits, pay employment taxes timely, or
failure to file timely returns. Further, it is unlikely that most
taxpayers understand the personal liability that can be assessed from
unpaid employment taxes. A liability that is not dischargeable in
bankruptcy.
While the education efforts
are beneficial, certainly there is an enforcement aspect of this
activity by the IRS. The IRS readily admits that two-thirds of federal
taxes are collected through the payroll tax system. With a reduced
budget, this activity makes good sense for the IRS. However, it is most
likely going to be most burdensome for small businesses.
No doubt early action is
best. If you know you have been falling behind on your payroll tax
obligations and need assistance planning before you hear from the taxing
authorities, feel free to call.
IRS Announces 2015 Inflation Adjustments on Several Tax Benefits and Retirement Adjustments
The IRS recently announced annual inflation adjustments for several tax provisions, which will apply to the 2015 tax year. Some of the affected provisions include: income tax rate schedules, the estate tax exemption, long-term care adjustments, and retirement adjustments. Below is a summary of those adjustments.
Tax Rates. Beginning in the 2015 tax year, the following tax rates will apply:
If the Taxable Income Is:
The Tax for Married Individuals Filing Jointly is:
Less than or equal to $18,450
10% of the taxable income
Over $18,450 but not over $74,900
$1,845 plus 15% of the excess over $18,450
Over $74,900 but not over $151, 200
$10,312.50 plus 25% of the excess over $74,90010% of the taxable income
Over $151,200 but not over $230,450
$29,387.50 plus 28% of the excess over $151,200
Over $230,450 but not over $411,500
$51,566.50 plus 33% of the excess over $230,450
Over $411,500 but not over $464,850
$111,324 plus 35% of the excess over $411,500
Over $464,850
$129,996.50 plus 39.6% of the excess over $464,850
If the Taxable Income Is:
The Tax for Heads of Households is:
Not over $13,150
10% of the taxable income
Over $13,150 but not over $50,200
$1,315 plus 15% of the excess over $13,150
Over $50,200 but not over $129,600
$6,872.50 plus 25% of the excess over $50,200
Over $129,600 but not over $209,850
$26,722.50 plus 28% of the excess over $129,600
Over $209,850 but not over $411,500
$49,192.50 plus 33% of the excess over $209,850
Over $411,500 but not over $439,000
$115,737 plus 35% of the excess over $411,500
Over $439,000
$125,362 plus 39.6% of the excess over $439,000
If the Taxable Income Is:
The Tax for Unmarried Individuals is:
Not over $9,225
10% of the taxable income
Over $9,225 but not over $37,450
$922.50 plus 15% of the excess over $9,225
Over $37,450 but not over $90, 750
$5,156.25 plus 25% of the excess over $37,450
Over $90,750 but not over $189,300
$18,481.25 plus 28% of the excess over $90,750
Over $189,300 but not over $411,500
$46,075.25 plus 33% of the excess over $189,300
Over $411,500 but not over $413,200
$119,401.25 plus 35% of the excess over $411,500
Over $413,200
$119,996.25 plus 39.9% of the excess over $413,200
If the Taxable Income Is:
The Tax for Married Individuals Filing Separate Returns is:
Not over $9,225
10% of the taxable income
Over $9,225 but not over $37,450
$922.50 plus 15% of the excess over $9,225
Over $37, 450 but not over $75,600
$5,156.25 plus 25% of the excess over $37,450
Over $75,600 but not over $115,225
$14,693.75 plus 28% of the excess over $75,600
Over $115,225 but not over $205,750
$25,788.75 plus 33% of the excess over $115,225
Over $205,750 but not over $232,425
$55,662 plus 35% of the excess over $205,750
Over $232,425
$64,989.25 plus 39.6% of the excess over $232,425
If the Taxable Income Is:
The Tax for Estates and Trusts is:
Not over $2,500
15% of the taxable income
Over $2,500 but not over $5,900
$375 plus 25% of the excess over $2,500
Over $5,900 but not over $9,050
$1,225 plus 28% of the excess over $5,900
Over $9,050 but not over $12,300
$2,107 plus 33% of the excess over $9,050
Over $12,300
$3,179.50 plus 39.6% of the excess over $12,300
Estate Tax Exemption.
The Estate Tax is a tax imposed on the transfer of property at a
person’s death, for any portion of the decedent’s gross estate that
exceeds the Federal Estate Tax Exemption. This year the estate tax
exclusion has increased from a total of $5,340,000 to $5,430,000. This
means that decedents who die in 2015 have an estate tax exclusion that
has increased by $90,000 from the previous year.
Long-term Care. Deductions for Long Term Care Insurance Premiums have increased slightly from 2014. The 2015 deductible limits under §213(d)(10) for eligible long-term care premiums are as follows:
Attained Age Before Close of Taxable Year
Limitation on Premiums
40 or less
$380
More than 40 but not more than 50
$710
More than 50 but not more than 60
$1,430
More than 60 but not more than 70
$3,800
More than 70
$4,750
Retirement Adjustments.
The elective deferral (contribution) limit for employees who
participate in 401(k), 403(b), most 457 plans, and the government’s
Thrift Savings Plan has increased from $17,500 to $18,000. In addition,
if you are 50 or over you can contribute an additional $6,000 as a
catch-up contribution. However, the limit on annual contributions to IRA
accounts remains unchanged at $5,500 with the catch-up contribution
limit remaining $1,000.
The deduction for taxpayers making
contributions to traditional IRA accounts is phased out gradually
starting at an Adjusted Gross Income (AGI) of $61,000 for single
taxpayers and heads of households, $98,000 for married couples filing
jointly (when the spouse who makes the IRA contribution is covered by a
workplace retirement plan), and $183,000 for an IRA contributor not
covered by a workplace retirement plan but who is married to someone who
is covered.
The deduction for taxpayers making
contributions to a Roth IRA is phased out gradually starting at an AGI
of $183,000 for married couples filing jointly and $116,000 for singles
and heads of households.
Lastly, the AGI limit for the saver’s
credit (retirement savings contribution credit) for low and moderate
income workers has also increased slightly for 2015. The credit is now
$61,000 for married couples filing jointly, $45,750 for heads of
household, and $30,500 for singles and married couples who file
separately.
If you have any questions about how these
adjustments might affect your tax situation, please feel free to contact
our office for further assistance.
Caraker Law Firm, P.C. 