The Supreme Court has declined to review a choice of the Fifth Circuit that the chief executive/CEO of a defunct airline was a accountable person who willfully failed to remit excise fees. The Fifth Circuit turned down the taxpayer’s promises that he relied on counsel in paying other creditors before IRS and that a post-9/11 law extending the day of payment excused payment completely. Background. Under Code Sec.
Facts. Michael Conway founded and operated National Airlines, Inc. (National), and was National’s chief executive officer (CEO), chief executive, and chairman of its plank of directors through the tax periods at concern (quarters ending Sept. Evidence showed that Conway understood of the unpaid excise fees for the 3rd one fourth of 2000, at the latest, when National declared personal bankruptcy.
Further, he understood of the unpaid taxes from 2001, at the latest, on Sept. 22, 2001, when Congress approved the Air Transportation Safety and System Stabilization Act (the Act) providing airlines a deferral of time within which to pay their excise taxes. 11 million, the majority of which shown the unpaid excise taxes from 2001. National never objected to the claim.
- 44 Arulampalam, Devereux, and Maffini (2007), Hassett and Mathur (2006), and Felix (2007)
- Step one: “I must have payment completely today.”
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The Chapter 7 trustee allowed IRS’s state in its entirety. On or around Mar. 14, 2003, IRS notified Conway of its purpose to evaluate trust account recovery penalties against him, which he appealed on, may 9 timely. IRS rejected his appeal and made its assessments against Conway under Code Sec.
Conway argued that the Act transformed the unpaid excise fees from trust funds to short-term loans, making the federal government somebody with the airlines effectively, and that he didn’t pay the excise fees based on counsel’s advice. He also argued that he wasn’t a accountable person, and that he didn’t action willfully.
District Court sides with IRS. The court also considered, and rejected ultimately, his argument that the Act excused payment of the excise taxes, finding that there is no sign that Congress intended to do anything more than defer their payment. The Act and accompanying IRS assistance unambiguously provided for an expansion of time to pay, rather than forgiveness of, the excise taxes. Appellate Court decision. The Court of Appeals for the Fifth Circuit affirmed the region court’s decision, agreeing that Conway was a responsible person (both before and during National’s personal bankruptcy) who willfully failed to pay fees.
Crunch the numbers, and opt for whichever option will save you more. Good advertising can play a pivotal role in the success of a little business – especially if you’re working on a local level. The expense of promoting your business can be significant, but thankfully you can deduct almost all types of advertising and promotion.
Beyond print out advertisements in local publications, this addresses costs associated with keeping a website, producing branded items, and sponsoring community events. Do you commonly take clients out to business lunches and dinners? Start saving those receipts. You are able to deduct up to 50 percent of food and beverage expenses often, including tips and taxes.
Keep an eye on whom you met with and what business you conducted during each meal by jotting down records on the back of your receipts. It requires only one minute, but it shall make things easier come tax season. This umbrella term covers a broad range of costs concerning employee payment.