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We have placed cookies on your device to help make this website better. You can adjust your cookie settingsotherwise we'll assume you're okay to continue. Privacy Policy. Home Search In. Previous Fields Gender Female. Profile Information Location southampton hampshire. Gutted im going to miss this one sounds like a great place to go, next year I will make sure i book my holiday round the gp dates.

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Risk free betting offers in compromise

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For low income taxpayers who have high success rates with offers in compromise, the equation in representing them often includes a balancing of the benefits of prolonged fighting about the underlying liability versus the possibility of a relatively quick and easy resolution through the offer process. Here, the amount offer is worth taking a hard look and the fact that it is an ETA offer means than a normal offer on doubt as collectibility is unavailable.

The clinic working the case and the client may have looked at the prospect of fighting the merits and decided that even if they might succeed, the cost would be much higher. Under the constructive receipt doctrine, a taxpayer is presumed to have received funds even when there is a theft. With respect to IRC Sec e , a theft loss is deductible in the year of discovery.

However the regs at 1. The Bogarts had to pursue legal remedies, however long they took, before they were entitled to the loss. They were trapped by an inequity in the law. But the court put it back in the hands of Appeals, and appears to left Appeals free to specifically address the issue and say no.

While that may not have happened, it is uncertain that this type of OIC will work in the future, as an Appeals Settlement Officer could still address the inequity and say no. A taxpayer may still need to pursue the matter in the tax court. It would seen prudent for a tax advisor in this circumstance to suggest claiming the loss in the year of discovery anyway, asserting that, even though recovery is being pursued, there is little actual prospect of recovery.

An audit could find against the taxpayer, but the same equity arguments raised in Bogart could be raised up front, potentially precluding the need for the OIC. Bogart may even be useful as precedent. Comment Policy: While we all have years of experience as practitioners and attorneys, and while Keith and Les have taught for many years, we think our work is better when we generate input from others.

That is one of the reasons we solicit guest posts and also because of the time it takes to write what we think are high quality posts. Involvement from others makes our site better. That is why we have kept our site open to comments. If you want to make a public comment, you must identify yourself using your first and last name and register by including your email.

If you do not, we will remove your comment. In a comment, if you disagree with or intend to criticize someone such as the poster, another commenter, a party or counsel in a case , you must do so in a respectful manner. We reserve the right to delete comments. If your comment is obnoxious, mean-spirited or violates our sense of decency we will remove the comment.

While you have the right to say what you want, you do not have the right to say what you want on our blog. Notify me of new posts by email. Love PT, and want to show your gratitude for the fact this amazing content is free? Click here to donate to TAPS and help fund legal representation of underserved taxpayers!

Read More…. Stephen J. Google Read More…. Nina E. Olson is the Executive Director of the Center for Taxpayer Rights, a c 3 organization dedicated to advancing taxpayer rights in the US and internationally. Professor Galvin has been teaching full-time at the University of Denver since October of and teaches courses in tax controversy representation, individual income tax, and tax research and writing. In the LITC, she teaches, supervises and assists students representing low income taxpayers with controversy and collection issues.

Prior to law school Caleb was the Tax Program Manager at Minnesota's largest Volunteer Income Tax Assistance organization, where he continues to remain engaged as an instructor and volunteer today. Patrick W. Procedurally Taxing is happy to have frequent guest bloggers who are experts in the area of tax procedure.

To read all the posts by our guest bloggers, please click here. This website is intended for general information purposes only and should not be considered legal advice on any particular situation. Visitors should obtain legal advice from their own attorney to suit their particular situation. The creation of an attorney-client relationship is not intended nor created by any communication through this website.

Procedurally Taxing Legal Tax Blog. Subscribe to our Blog Enter your email address to subscribe and receive notifications of new posts by email. About the Blog. March 28, by Guest Blogger 3 Comments. Comments Eric Rasmusen says. March 28, at am. Keith Fogg says. March 31, at pm. A J Decaria EA says. April 2, at pm. Keith Fogg T. Stephen Olsen Stephen J. If Cuomo is warming to statewide mobile betting, even its most bullish supporters acknowledge it would be just a tiny fix for the massive budget hole.

Until — or more critically if — Washington channels state-level funds, New York sports betting is still an afterthought. However, the latest signs from Capitol Hill indicate New York may not have many other options. Republicans instead have fought for expanded COVID liability protections for businesses, a non-starter for Democrats. To compromise, reports indicate Republicans will drop the liability protections if Democrats drop the state funding. Now in his third term as governor, Cuomo is the most influential state Democrat over a legislature that will have Democratic supermajorities in both chambers beginning with the session.

Facing a separate gaping budget deficit in the lingering aftermath of the Great Recession, Cuomo pushed for a constitutional amendment in that would allow four upstate commercial casinos and for all four to open sportsbooks should the federal sports betting ban in place at the time be lifted.

Instead of a competitive, statewide mobile option that would almost instantly make New York sports betting a multimillion-dollar enterprise, Cuomo has been content with the slow trickle of a handful of retail sportsbooks. Some critics also fear it opens another possible lawsuit in a state that has already battled daily fantasy operators DraftKings and Manhattan-based FanDuel in court for years.

Mobile sports betting backers in the legislature have dismissed the legal need for a constitutional amendment, a position reaffirmed by multiple gaming industry legal experts. Assembly Member J. Gary Pretlow is arguably the biggest proponent of them all. The biggest Assembly backer of failed sports betting efforts each of the last three years, Pretlow said another chance could come as part of a possible revenue bill that will need to be in place by early next week. If that fails, lawmakers will have to start over again when the session begins in January.

In the statehouse, sports betting will have to fight in the gauntlet of budgetary negotiations, a grueling, frenetic endeavor in Albany in even the best of financial times. By law, the budget must be submitted by April, giving sports betting backers a small window to finally legalize mobile wagering.

PROPHET BETTING WEBSITES

Here, the appeals officer never explicitly addressed the equity argument, and remand was therefore required. Indeed, perhaps the most common area where this occurred is in innocent spouse cases. While it appears to be getting better, the IRS would almost routinely deny a claim for innocent spouse relief without providing any reasoning. See sec. But at the administrative level repondent did not consider whether the theft loss constituted exceptional circumstances—even though petitioners requested relief on public policy and equity grounds.

The administrative record indicates that respondent did not consider those grounds but focused solely on economic hardship grounds. How appalling! I bet the problem is in the regulations, not the statute. If it is, then the Bogarts should argue that the regulations fail Chevron, in their case at least, by creating a recognition rule that defeats the unambiguous purpose of the regulation given the existence of a 3-year loss period.

I do not know the issue well enough to have an opinion on the likelihood of success in attacking the regulations if the problem is in the regulations. Even if a low income tax clinic agreed to handle the attack, the toll of waiting for several years and the effort necessary to succeed might not equal the benefit of a quick resolution. For low income taxpayers who have high success rates with offers in compromise, the equation in representing them often includes a balancing of the benefits of prolonged fighting about the underlying liability versus the possibility of a relatively quick and easy resolution through the offer process.

Here, the amount offer is worth taking a hard look and the fact that it is an ETA offer means than a normal offer on doubt as collectibility is unavailable. The clinic working the case and the client may have looked at the prospect of fighting the merits and decided that even if they might succeed, the cost would be much higher. Under the constructive receipt doctrine, a taxpayer is presumed to have received funds even when there is a theft. With respect to IRC Sec e , a theft loss is deductible in the year of discovery.

However the regs at 1. The Bogarts had to pursue legal remedies, however long they took, before they were entitled to the loss. They were trapped by an inequity in the law. But the court put it back in the hands of Appeals, and appears to left Appeals free to specifically address the issue and say no. While that may not have happened, it is uncertain that this type of OIC will work in the future, as an Appeals Settlement Officer could still address the inequity and say no.

A taxpayer may still need to pursue the matter in the tax court. It would seen prudent for a tax advisor in this circumstance to suggest claiming the loss in the year of discovery anyway, asserting that, even though recovery is being pursued, there is little actual prospect of recovery. An audit could find against the taxpayer, but the same equity arguments raised in Bogart could be raised up front, potentially precluding the need for the OIC.

Bogart may even be useful as precedent. Comment Policy: While we all have years of experience as practitioners and attorneys, and while Keith and Les have taught for many years, we think our work is better when we generate input from others.

That is one of the reasons we solicit guest posts and also because of the time it takes to write what we think are high quality posts. Involvement from others makes our site better. That is why we have kept our site open to comments. If you want to make a public comment, you must identify yourself using your first and last name and register by including your email.

If you do not, we will remove your comment. In a comment, if you disagree with or intend to criticize someone such as the poster, another commenter, a party or counsel in a case , you must do so in a respectful manner. We reserve the right to delete comments. If your comment is obnoxious, mean-spirited or violates our sense of decency we will remove the comment. While you have the right to say what you want, you do not have the right to say what you want on our blog.

Notify me of new posts by email. Love PT, and want to show your gratitude for the fact this amazing content is free? Click here to donate to TAPS and help fund legal representation of underserved taxpayers! Read More….

Stephen J. Google Read More…. Nina E. Olson is the Executive Director of the Center for Taxpayer Rights, a c 3 organization dedicated to advancing taxpayer rights in the US and internationally. Professor Galvin has been teaching full-time at the University of Denver since October of and teaches courses in tax controversy representation, individual income tax, and tax research and writing. In the LITC, she teaches, supervises and assists students representing low income taxpayers with controversy and collection issues.

Prior to law school Caleb was the Tax Program Manager at Minnesota's largest Volunteer Income Tax Assistance organization, where he continues to remain engaged as an instructor and volunteer today. Patrick W. Procedurally Taxing is happy to have frequent guest bloggers who are experts in the area of tax procedure.

To read all the posts by our guest bloggers, please click here. This website is intended for general information purposes only and should not be considered legal advice on any particular situation. Visitors should obtain legal advice from their own attorney to suit their particular situation. The creation of an attorney-client relationship is not intended nor created by any communication through this website. Procedurally Taxing Legal Tax Blog. This legislation would have permitted online and mobile wagering, authorized the Gaming Commission to establish regulations and called for a tax rate of 8.

Lawmakers struck a compromise and included a 0. In a press release announcing the introduction of the bill, Bonacic said this:. If allowed, sports betting will be a revenue enhancer for education in New York. We have the chance to ensure our sports betting statute is fully developed and addresses the needs of the state and all stakeholders so we can hit the ground running if and when we can authorize and regulate sports betting.

That bill did not make it through the process before the end of the legislative session. The market demand is clearly there and has been more than demonstrated over in New Jersey where the majority of wagers made via mobile devices already outstrips those made in-person. International online sports betting company Bet reached an agreement with Resorts World Catskills in November to offer online and in-person wagering pending regulatory approval.

Under that agreement, Fox Bet will provide support services to a retail sportsbook at the Akwesasne Mohawk Casino Resort with options to also operate mobile sports betting, online poker and online casino games if permitted by state law. Rivers Casino Schenectady has already begun construction on a retail sportsbook and will likely look to launch online betting under the BetRivers.

PointsBet also has some kind of deal in place with Tioga Downs, but it is unclear how that agreement would interact with the deal FanDuel already has in place with the same racetrack. All we have to go on is an early press release announcing the launch of PointsBet NJ that mentioned the Tioga Downs partnership in passing.

Caesars Casino will establish itself in the New York sports betting market through a deal reached with the Oneida Indian Nation in January A press release issued at the time did not mention mobile betting. Horse racing betting is widespread and readily available across New York.

The Horse Racing division of the New York State Gaming Commission oversees the conduct of racing and parimutuel wagering within the state. The Commission. Under New York law, advance deposit wagering online betting may be offered by licensed operators. The most prominent online parimutuel wagering providers licensed in NY include:. Five government-run public benefit corporations control off-track betting locations OTBs across the state.

Each corporation maintains a current list of OTB locations below:. New York continues to be one of the most trouble states for daily fantasy sports despite passing legislation to legalize the activity in Fantasy sites first came to New York before the legality of fantasy contests was clear. After several years of operating in the state, the major DFS sites were forcibly ejected due to an unfavorable opinion from the Attorney General and subsequent cease-and-desist orders.

He issued a pair of cease-and-desist letters to FanDuel and DraftKings that ordered both sites to stop operating within the state immediately. Major providers FanDuel and DraftKings fought the order, and experienced a number of ups and downs over the next year. They later pulled out again as a part of an agreement to help push two pro-legalization bills that were progressing through the state legislature.

The companion bills seeking to legalize and regulate fantasy sports in New York eventually made their way through the legislature to land on the desk of Governor Andrew Cuomo. He signed the bills on August 3 rd of to finally legalize real money daily fantasy sports. Unfortunately for DFS players, the story does not end there. Anti-gambling groups sued Governor Andrew Cuomo shortly after the passage of the fantasy sports law. The lawsuit is ongoing to this day. In , an appeals court ruled against the daily fantasy industry by declaring the law unconstitutional.

New York has flirted with legalizing online gambling for years, particularly online poker. Lawmakers have shown no real interest in passing legislation to legalize online casinos in NY, but they have considered multiple bills to authorize online poker.

Pro-gambling lawmakers have introduced bills every year since in an attempt to authorize online poker in New York. Those efforts have failed to yield results to date, but the effort continues to this day. Senator Joseph Addabbo has played a key role in pushing lawmakers to authorize online poker over the years.

His efforts include the introduction of S 18 in and again in , a bill that would classify poker as a game of skill rather than gambling. The bill failed to progress in , pushing New York online poker efforts over to Senator Bonacic introduced bill S full text in March of to specifically address online poker. In short, the bill sought to legalize online poker and issue licenses to up to 10 operators inside the state of New York.

The bill wanted to address the dangers of offshore poker by regulating its own industry here at home. The licensing and regulatory measures would have ensured operators were held to a high standard while at the same time collect tax revenue for an activity that was already taking place anyways via offshore poker sites.

This would have effectively banned PokerStars from New York forever. The legislation also would have allowed New York to enter player-sharing agreements with other states that legalize online poker. Even today, this is a key piece of any poker legislation because it would allow players in New York to sit at tables with players from other states. The end result of any player sharing agreements would be greater liquidity for poker sites and more games for players.

S never made it past the Racing, Gaming and Wagering committee. Bonacic introduced similar legislation in and also to no avail. The odds of something being passed over the next few years remain favorable. Real life gambling and online poker are two completely different things of course, but people in most cases are generally even more receptive of poker than of games of chance. If the people are willing to accept casino gambling, they are probably willing to accept poker.

The New York Lottery offers a subscription service for players who live within state lines. Players may manage up to 10 subscriptions at a time and either choose their own numbers or allow the lottery system to provide random picks. No other third-parties are authorized to sell NY Lottery products. Skip to content.

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