And still I will explain what that federal lien is about...
Some fools like you should definitely know my life more detailed ...
We handled 167,000 tax files of which 10,800 files were from employees of then largest tech software company then that issued employment letters to their employees telling that their employment is for < 12 months in the united states and during their stay in the united states they will be paid deputation allowance and issued W2 taxing that deputation allowance as wages in Box 1. When someone is paid deputation allowance and not a transient worker, and their job at client location is temporary then Tax Code allows them Unreimbursed Job related expenses. The deputed software employees of this large company from India were temporary and replaceable consultants with no control from taxpayer as to their deputation period. Most of the these consultants were on this temporary position and department when inquired seeing a pattern of expense claim we presented all the documentation and even consents secured from taxpayer for filing their tax returns. Department then asked the taxpayers to produce evidence that their employer(s) have not reimbursed and asked certification that their placement on consultation is temporary. I was thoroughly examined and investigated at the IRS Chicago office and office of professional conduct Washington DC and I have explained my position and told the Department that it cannot viewed as a pattern because entire employees were in that temporary position. Of the total 167,000 files, Department researched that 1,200 of them were in positions for more than 12 months and that turns their job into permanence if in on consulting. The third thing was these people could not produce evidence to the department as company refused to offer them such support. I appealed to the treasury that onus of evidence should come from the source that is responsible for and in these cases it is the employer who should substantial ... IRS then levied a minimum 1,000 penalty on these 1,200 cases in 2011 then amounting to $1,200,000 and subsequently investigated the employer who could not submit this evidence because those consultants were on L1 VISA and under L1 visa they cannot work at any location other than the office of the employer. They were penalized with $200 Million dollars as penalty for this violation. I appealed and substantiated and appealed for 12 years. And in 2023 entire of this liability is written off by IRS. Then the question may arise when so filings ? We conducted tax practice between 2002 - 2011. On a tax customer count of 167,000 filed through us for more than 5 years, these 1,200 cases that too for which we are not responsible for we were levied penalty. And we fought this and appealed to the Office of Professional conduct and even presented our tax amendments that IRS approved on job expenses. After 12 years, the liens are lifted. The entire 1.884 million that accumulated from 1.2 M in 2011 through 2023 got lifted. We have not conducted anything above the law -- and I am taking this disclosure as a publicly made statement,
Laxmi Prasad
News 
Market Data 
Discover 
AI
