Hall Law Group, PLLC

Listen to the latest episode of and find out why the is more like a kraken 🐙 than any other multi-tentacled being . . . 💡 oh, and more 𝐢𝐦𝐩𝐨𝐫𝐭𝐚𝐧𝐭𝐥𝐲, 💡 listen to the attorneys who filed plaintiff's claim alleging that Specialists, LLC, committed serious RICO violations and other misdeeds.

Thank you so much, Janine Campanaro and Jacob Langley!

Please like and subscribe on YouTube to ensure you know about new episodes as they drop!

ERC Litigation Update: Guinea Pig Predicament interviews the attorneys who filed Plaintiff's claim alleging that Specialists, LLC, committed serious RICO violations and other misdeeds. ...

Killer Bill is back in the news. 📰😏

This is us wondering if business owners with legitimate claims will ever get their money. 🤧

Hop on over to LinkedIn for more audit baiting and salty tax commentary. 👯‍♀️



https://www.instagram.com/reel/DAHEkQCp9EV/?igsh=bzF4N3k1NHV6c2Vx

#ERC Killer Bill is back in the news. 📰😏 This is us wondering if business owners with legitimate claims will ever get their money. 🤧 Hop on over to LinkedIn for more salty tax commentary and audit baiting. 👯‍♀️ #employeeretentioncredit #taxpolicy #taxplaining #congress #proposedbill

Did you know...

..We also handle back tax issues for our clients? We know this can be a touchy subject that many do not want to ask about or bring up to friends, family, or even other advisors.

There are many reasons an individual or business owner may get behind on their taxes. Some of these include an illness, death in the family, loss of income, or other reasons. If these reasons are properly documented, the IRS may even agree to eliminate some penalties as a result.

You can schedule a confidential, free consultation and learn about your options here:

https://calendly.com/ashleehall/tax-resolution-consultation

Tax Resolution Consultation - Ashlee Hall

New blog from ... This might be my favorite critique thus far of .

Highlights below 🦆

🦆 "By contrast, the IRS did not subject disallowed ERC claims to an examination; rather, the IRS conducted a risk-scoring analytic process. For these disallowed claims, the IRS’s analytics determined the claim showed a high risk of being incorrect without first conducting an ."

{In other words, as Mary Lundstedt put it... an without the protections normally afforded taxpayers in an exam. Huh.}

🦆 "Specifically, when a taxpayer responds to a notice of claim disallowance they believe they are submitting a protest of the denial to Appeals, which is standard practice. However, this response will generally first be reviewed by the IRS and sent to a Revenue Agent for consideration."

🦆 "The IRS is not calling this review an examination, but if it looks like a duck and walks like a duck…"

🦆 "It is only after this quasi-exam that the taxpayer’s response would be sent to Appeals."

🦆 "Another stark difference from normal IRS processes is the processing pipeline in which a taxpayer’s response to a notice of claim disallowance will travel. In fact, it almost turns normal IRS processes on its head."

🦆 "It is important for taxpayers and practitioners to understand that any IRS process involving a review of facts and circumstances, along with a referral to Appeals for its consideration, is going to be lengthy."

Based on we practitioners' experience with the IRS in defending ERC claims thus far (you know who you are), I am curious to see whether these Revenue Agents or Appeals Officers truly do review the facts and circumstances.

Like I’ve said… time to dust off ye olde Taxpayer Bill of Rights 📜

Link to article in comments.

THE MORATORIUM ENDS... sort of.

🏈 Well, that'll move the chains at least. This is like a first down of sorts in that the IRS indicated today that it intends to slowly begin processing claims filed between September 14, 2023 and January 31, 2024, the previously-proposed end date of ERC as set forth in the failed . So, in a sense the still isn't over... it's just been moved down the field. Good news for taxpayers.

🏈 Underwhelmingly and in the latest example of , the IRS doubled-down on its assertions that the majority of disallowance letters in the latest round were accurate, stating, "...errors are relatively isolated and that more than 90% of disallowance notices were validly issued." Curious as to how they could possibly know this considering it's likely too early for any written protests to have been processed. I find it interesting that the number of inaccurate letters is estimated to be what the considers to be . I asked my LinkedIn followers to comment if their clients received a disallowance letter in the latest wave that was inaccurate so we can confirm that the errant letters must have been "isolated" to this corner of the internet. That is the only logical explanation.

🏈 For those in the 10%, the IRS noted that "in limited cases where claims can be proven to have been improperly denied, the agency will work with taxpayers to get it right" and reminded taxpayers that regardless of whether the disallowance letter contained appeals language or not (while admitting language was omitted from some letters) the taxpayer does have the right to an with the IRS Independent Office of Appeals.

🏈 Finally, the IRS projects payments of 50,000 low-risk claims will begin in September with additional payments going out in subsequent weeks. The IRS anticipates adding another large block of additional low-risk claims for processing and payment in the fall. I am curious to see the low-risk claim criteria and how it compares to businesses that received a disallowance letter based on incorrect or inaccurate information.

I typically lean toward optimism rather than skepticism, but after everything we've seen to date on how ERC has been handled, I am skeptical of the IRS getting this next wave right. We'll see.

No announcement on revival details yet, but those should be forthcoming any day.

In other news, happy football pre-season. 🍂

Full news release in comments ⤵

Taxplaining🎙️
Mary Lundstedt

THE MORATORIUM ENDS... sort of. 🏈 Well, that’ll move the chains at least. This is like a first down of sorts in that the IRS indicated today that it intends to slowly begin processing #ERC claims filed between September 14, 2023 and January 31, 2024, the previously-proposed end date of ERC as set forth in the failed #ERCKillerBill. So, in a sense the #moratorium still isn’t over... it’s just been moved down the field. Good news for taxpayers. 🏈 Underwhelmingly and in the latest example of #IRSmath, the IRS doubled-down on its assertions that the majority of disallowance letters in the latest round were accurate, stating, “...errors are relatively isolated and that more than 90% of disallowance notices were validly issued.” Curious as to how they could possibly know this considering it’s likely too early for any written protests to have been processed. I find it interesting that the number of inaccurate letters is estimated to be what the #IRS considers to be #nominal. I asked my LinkedIn followers to comment if their clients received a disallowance letter in the latest wave that was inaccurate so we can confirm that the errant letters must have been “isolated” to this corner of the internet. That is the only logical explanation. 🏈 For those in the 10%, the IRS noted that “in limited cases where claims can be proven to have been improperly denied, the agency will work with taxpayers to get it right” and reminded taxpayers that regardless of whether the disallowance letter contained appeals language or not (while admitting language was omitted from some letters) the taxpayer does have the right to an #appeal with the IRS Independent Office of Appeals. Continued in comments… ⤵️ @taxplaining @mlundstedt #taxplaining #employeeretentioncredit #IRSupdates #taxlaw #taxpolicy

“…But if the high-risk group actually includes many valid claims, the government could be holding up tens of billions of dollars in legitimate refunds from eligible small employers—and owe them interest.”

Evidently, according to the , my restaurant client in Florida who received a disallowance for Q2 2020, my furniture store client in Ohio who received a disallowance for its 2020 claims, my nail salon clients in Pennsylvania, Texas, and Colorado, my chiropractor client in California, my photographer in New Jersey, and my restaurant clients in New York, Virginia, and Utah are in the “highest risk” group.

“IRS Commissioner Danny Werfel said he was confident that 90% of recent denials were correct and that the agency is on the right track.”

If is correct, 100% of the letters I have personally seen thus far must fall into the 10% group that Werfel admits may contain errors. 🤔

Read on for a quote from yours truly.

https://www.wsj.com/politics/policy/irs-rejections-covid-tax-credit-92013033?st=3lhcsgwef1fzzsy&reflink=article_copyURL_share

Hall Law Group, PLLC is pleased to announce that Ashlee Hall is one of the newest Contributing Editors to Thomson Reuters PPC’s Practitioners Tax Action Bulletin.



Thomson Reuters

What is “proactive tax planning”? 🧐

Proactive planning is also known as “tax strategy,” or “tax advisory,” but these terms typically mean the same thing.

Your or is really good at recording history. Proactive tax planning takes place throughout the year. It takes a look at that history in the form of your prior year’s tax returns, discusses any changes to the current or upcoming tax year along with your goals for the future, and comes up with a comprehensive that is tailored to your situation.

Your taxes, but less.

What is “proactive tax planning”? 🧐 Proactive #tax planning is also known as “tax strategy,” or “tax advisory,” but these terms typically mean the same thing. Your #accountant or #CPA is really good at recording history. Proactive tax planning takes place throughout the year. It takes a look at that history in the form of your prior year’s tax returns, discusses any changes to the current or upcoming tax year along with your goals for the future, and comes up with a comprehensive #taxplan that is tailored to your situation. Your taxes, but less. #taxstrategy #taxtips #taxlaw #taxplanning #smallbusiness #selfemployed

Check out HLG Owner & Principal Attorney Ashlee Hall’s CIO Views cover story below ⬇️

The digital magazine version can be found here: https://lnkd.in/gwP_TvwR

Web versision: https://cioviews.com/ashlee-hall-the-observant-leader-helping-navigate-the-complex-erc-landscape/




📸: Jennifer Junkins

Earlier this year, our founder Ashlee Hall shared her thoughts with CanvasRebel on advising clients, being a connector, digesting the tax code, working in a tractor dealership, creatively solving problems, and pivoting.

You might learn something you didn't know: https://canvasrebel.com/meet-ashlee-hall/



📸: Jennifer Junkins

Meet Ashlee Hall We're excited to introduce you to the always interesting and insightful Ashlee Hall. We hope you'll enjoy our conversation with Ashlee below. Ashlee , appreciate you joining us today. What’s the best advice you ever gave to a client? How did they benefit / what was the result? In advising any lega...

We are a boutique tax advisory firm with nearly two decades of experience. By using court-tested and IRS-approved strategies, we identify proactive solutions to help business owners save money on taxes legally.

Your taxes, but less.