net-worth method. The procedure the Internal Revenue Service uses to determine the taxable income of a taxpayer who does not keep adequate records. • The change in net worth for the year determines the taxpayer’s gross income, after taking into account nontaxable receipts and nondeductible expenses. [Cases: Internal Revenue 4530. C.J.S. Internal Revenue §§ 645, […]
Negligence arising out of the disregard of tax-payment laws, for which the Internal Revenue Service may impose a penalty — 5% of the amount underpaid. IRC (26 USCA) § 6651(a). [Cases: Internal Revenue 5219. C.J.S. Internal Revenue § 824.]
Tax. A written contract between a taxpayer and the Internal Revenue Service to resolve a tax dispute. [Cases: Internal Revenue 4761. C.J.S. Internal Revenue § 654.]
A corporation formed to give a short-term venture the appearance of a long-term in-vestment in order to portray income as capital gain, rather than profit. • The corporation is typically formed for the sole purpose of purchasing property. The corporation is usu. dissolved before the property has generated sub-stantial income. The Internal Revenue Service treats
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W-2 form. Tax. A statement of earnings and taxes withheld (including federal, state, and local income taxes and FICA tax) during a given tax year. • The W-2 is prepared by the employer, provided to each employee, and filed with the Internal Revenue Service. Cf. W-4 FORM. [Cases: Internal Revenue 4849. C.J.S. Internal Revenue §§
correspondence audit 〈美〉信函式纳税审计 国内税务署〔Internal Revenue Service〕通过邮件进行的审计活动。通常由该署写信要求纳税人确认某一特定的税务减免，纳税人则填报特定表格或寄回证明材料之副本或其他佐证便可。 (→audit)
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thirty-day letter. A letter that accompanies a revenue agent’s report issued as a result of an Internal Revenue Service audit or the rejection of a taxpayer’s claim for refund and that outlines the taxpayer’s appeal procedure before the Internal Revenue Service. • If the taxpayer does not request any such procedure within the 30-day period,
step-transaction doctrine. A method used by the Internal Revenue Service to determine tax liability by viewing the transaction as a whole, and disregarding one or more nonsubstantive, intervening transactions taken to achieve the final result. — Also termed step-transaction approach. [Cases: Internal Revenue 3071. C.J.S. Internal Revenue §§ 13–14.]
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Office of Tax-Shelter Analysis. An office in the U.S. Internal Revenue Service responsible for identifying and investigating questionable tax shelters. • The Office was created in 2000. — Abbr. OTSA.
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private letter ruling 〈美〉个别回复 指国内税务署〔Internal Revenue Service〕应纳税人请求就该纳税人打算进行的特定交易中所涉及的税法解释及具体适用问题所作的书面解答。该词亦称letter ruling。
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