Bomar Law Firm Atlanta Tax Attorney | Former IRS Chief Counsel Lawyer | Atlanta, GA 2026-05-28T16:31:33Z https://www.atlantataxattorney.com/feed/atom/ WordPress /wp-content/uploads/sites/1404226/2023/11/cropped-bomar-site-icon-32x32.png On Behalf of Bomar Law Firm <![CDATA[What should you know about the Kwong Interest Ruling?]]> https://www.atlantataxattorney.com/?p=54611 2026-05-22T15:46:43Z 2026-05-12T14:03:07Z In Kwong v. United States, the U.S. Court of Federal Claims ruled that the COVID-19 disaster period, which ran from January 20, 2020, through July 10, 2023, required that federal tax deadlines were automatically extended for that period. Because of the way the Internal Revenue Service (IRS) was computing interest and penalties during that period, many taxpayers were overcharged.  Taxpayers who paid interest on liabilities that were tied to deadlines during that established disaster period may have a strong basis for seeking refunds or abatements. This includes conservation easement investors who settled with the IRS during that period and paid interest during it. Even though this matter isn’t fully resolved in the court system yet, taxpayers should still abide by the set deadlines. One of these is filing a refund or abatement claim by July 10, 2026. 

Be aware of potential conflicts of interest

Getting the claim filed prior to the deadline is critical because it may preserve your rights to a refund or abatement. However, you should ensure that you work with a firm that doesn’t have an established conflict of interest in these matters.  Many firms that are advertising Kwong-related services for conservation easement investors previously represented promoters who were pushing these troubled deals. Because of this, it’s critical to find out if the firm you’re considering is in that position.  Another consideration for investors is the fee structure for representation. Some firms are offering flat-fee arrangements, but adding contingency fees to the deal. This extra expense could be costly for investors who are already dealing with significant tax burdens.  At Bomar Law Firm, our conservation easement lawyers are committed to representing only investors. We haven’t represented promoters or the partnerships they were pushing for. We also offer a transparent flat-fee structure without adding extra fees.  Conservation easement investors who believe they have a claim based on Kwong and haven’t filed yet should act quickly to learn their rights. If a claim is appropriate, the deadline is approaching quickly, so getting it filed now is important.   ]]> On Behalf of Bomar Law Firm <![CDATA[What should you know about Georgia’s Tax Court transition?]]> https://www.atlantataxattorney.com/?p=54609 2026-05-12T12:59:46Z 2026-05-12T12:59:46Z Georgia residents who have a pending dispute regarding taxes should become familiar with a significant change that’s coming on July 1, 2026. The Georgia Tax Tribunal is being replaced by the Georgia Tax Court, which will move tax appeals into the judicial branch. This offers taxpayers a more formal and impartial forum to resolve tax disputes.  The Georgia Tax Tribunal was part of the executive branch, so the move to the judicial branch means that there are some procedural changes coming. The Georgia Tax Court will follow the Georgia Civil Practice Act and rules of evidence, so people utilizing this process will find that there are stronger due process protections. 

Appeals process

One of the most impactful changes is that the Georgia Tax Court offers a direct appeal to the appellate court. This enables individuals to bypass the Fulton County Superior Court and the discretionary appeal process that followed. By having the ability to launch a direct appeal, filers will have a less costly and more streamlined process for resolving their issues.  Another change is that the new court has a broader jurisdiction than the Georgia Tax Tribunal. On top of tax cases, the Georgia Tax Court can also hear Department of Revenue actions and constitutional claims that would normally require a separate proceeding. 

Making the transition

The transition from the Georgia Tax Tribunal to the Georgia Tax Court will be automatic. Any cases that are pending with the Tax Tribunal as of June 30, 2026, will transfer to the new court. There is no requirement for the taxpayer to request the transfer.  People who want to launch an appeal will need to do so swiftly. For example, most assessment appeals have a 45-day window for appealing, which still applies even through and after the transition.  While this change might seem minor to some, it’s a major change that requires people with issues that will be heard by this court to work with someone who’s familiar with the new tax-related procedures. The June 30 transition date is approaching quickly, so swift action is necessary to learn the options and move forward with the best option for your case.   ]]> On Behalf of Bomar Law Firm <![CDATA[Tokenization of real-world assets in Georgia]]> https://www.atlantataxattorney.com/?p=54517 2025-09-22T16:52:11Z 2025-09-26T16:51:11Z Tokenization is changing how people buy, sell and invest in assets. In Georgia, it is reshaping agriculture, real estate and finance while raising new legal questions for investors and businesses.

What tokenization means

Tokenization turns real-world assets into digital tokens on a blockchain. These tokens can represent farmland, real estate, commodities or bonds. Tokenization can:
  • Increase liquidity: It makes hard-to-sell assets like real estate or orchards easier to trade.
  • Allow fractional ownership: It lets investors buy smaller, affordable shares of high-value assets.
  • Streamline transactions: It uses smart contracts to automate transfers and reduce paperwork.
  • Enhance transparency: It records ownership and transfers on blockchain ledgers.
These benefits explain why tokenization is growing worldwide and why Georgia has started to adopt it.

Tokenization projects in Georgia

Georgia is becoming a testing ground for tokenized assets. Farmway Technologies launched a $100 million project to tokenize almond orchards, giving investors fractional ownership of farmland. Real estate tokenization also lets investors purchase small stakes in properties across the state. In Atlanta, fintech firms now offer tokenization services that help businesses convert assets into blockchain-based records. This may expand access to capital but also brings regulation. Under the Georgia Money Transmitter Act, tokenization platforms that move money or “monetary value” may need licenses. Courts still must decide whether digital tokens count as monetary value.

The role of major platforms

Global platforms like Chainlink and Ondo Finance lead some of the biggest tokenization projects. Chainlink provides data systems to ensure tokenized assets match real-world information while Ondo focuses on tokenizing financial products like U.S. Treasury bonds. These platforms set standards that smaller Georgia projects may follow as they enter regulated markets.

Why legal guidance matters

For Georgia investors and businesses, tokenization brings opportunity but also risk. Regulators have not answered all questions and the IRS has shown more interest in crypto and tokenized assets. If regulators treat a tokenized asset as a security or monetary instrument, you may face heavy compliance rules. Because tokenization touches state and federal law, it is recommended to consult an attorney before you act. An experienced lawyer can explain if you need licenses, what tax rules apply and how to avoid IRS disputes.]]> On Behalf of Bomar Law Firm <![CDATA[Altcoin Season Is Here: What Happens If You Ignore Your Crypto Tax Obligations?]]> https://www.atlantataxattorney.com/?p=54515 2025-09-22T16:21:05Z 2025-09-22T16:21:05Z Altcoin season can feel exciting when digital assets rise in value. But if you fail to report your crypto on your taxes in Georgia, you risk serious financial and legal trouble.

How cryptocurrency is taxed in the United States

The IRS treats cryptocurrency as property, not as money. General tax rules for property apply. When you sell, trade or use crypto to buy something, you create capital gains or losses. When you mine, stake or accept crypto as payment, the IRS counts it as taxable income.

Penalties for not reporting crypto

If you fail to report cryptocurrency, the IRS can punish you for tax fraud or tax evasion. These are federal crimes with harsh penalties:
  • Civil penalties: Up to 75% of unpaid taxes plus interest.
  • Individual fines: Up to $100,000.
  • Corporate fines: Up to $500,000.
  • Prison time: Up to 5 years in severe cases.
The IRS takes unreported crypto very seriously.

How the IRS tracks crypto transactions

Crypto is not invisible to regulators. The IRS uses several tools to find unreported activity:
  • Exchange reporting: Platforms like Coinbase and Kraken send Form 1099s to the IRS.
  • Blockchain analytics: Agents trace wallet addresses and transactions through public ledgers.
  • Legal summons: “John Doe” summons can force exchanges to hand over user data.
With the rollout of new reporting forms in 2025 such as Form 1099-DA, crypto enforcement is expected to intensify.

Understanding crypto tax evasion

The IRS classifies crypto tax evasion into two categories:
  • Evasion of assessment: Omitting or misreporting income such as failing to disclose gains or staking rewards.
  • Evasion of payment: Hiding assets to avoid paying an assessed liability.
Both carry severe financial and legal risks. Even small unreported gains can raise red flags if discovered in an audit.

Altcoin gains and your future

Altcoin season can be financially rewarding but ignoring your reporting obligations may turn success into a costly mistake. Understanding the tax treatment of crypto is critical if you plan to use gains to build long-term wealth or retirement savings.  If you have significant crypto holdings or complex trading activity, consulting an attorney may be wise. Working with an attorney may help you better protect your investments, review IRS guidance and keep detailed transaction records.]]> On Behalf of Bomar Law Firm <![CDATA[How can I make the most of altcoin season?]]> https://www.atlantataxattorney.com/?p=54423 2025-07-21T20:01:13Z 2025-07-21T20:01:13Z The allure of altcoin season The excitement stems from the possibility of altcoins gaining traction and achieving exponential growth. Investors, driven by the potential for high returns, often wait years for the next altcoin season — and it appears the next season may be upon us. Common indicators of the beginning of the next altcoin season often include decreased interest in bitcoin and shift of capital investment into altcoins. Experts in the field note that the recent passage of the GENIUS Act with its focus on regulatory framework to help provide stability could increase institutional demand for altcoins and further trigger the next altcoin season.

Be aware of potential legal issues

Before diving into what may be the next altcoin season, it is important to keep the following legalities in mind:
  • Regulatory compliance: Investors must ensure their activities comply with local and international regulations. This includes understanding securities laws and tax obligations.
  • Fraud and scams: The cryptocurrency market is rife with fraudulent schemes, especially during altcoin season. Investors should conduct thorough due diligence to avoid falling victim to scams.
  • Contractual obligations: Investors should review the terms and conditions of exchanges and wallets. Understanding these agreements is crucial to avoid legal disputes.
  • Intellectual property rights: Altcoin projects often involve proprietary technology. Investors must respect intellectual property laws to prevent infringement issues.
Investors who address these potential issues can mitigate risks and enhance their investment strategies. Altcoin season presents exciting opportunities for investors, but it also comes with significant legal challenges. Understanding the regulatory environment and legal obligations is vital for anyone hoping to retire on their altcoin investments. By prioritizing legal compliance and conducting thorough research, investors can work their way through the complexities of the cryptocurrency market with confidence. While the allure of altcoin season is undeniable, a prudent approach helps to better ensure that dreams of financial freedom are grounded in reality.]]> On Behalf of Bomar Law Firm <![CDATA[Bomar Law Firm Receives Prestigious 2025 ThreeBestRated® Business Excellence Award]]> https://www.atlantataxattorney.com/?p=54418 2025-07-21T16:45:17Z 2025-07-21T16:39:18Z Bomar Law Firm, a leading name in tax litigation in Georgia, has proudly received the 2025 ThreeBestRated® Award of Excellence. This marks the eighth consecutive year the firm has been honored, showcasing their unwavering commitment to excellence in the field of tax law nationwide.  Founded by former IRS Chief Counsel Calvin Bomar, the firm has consistently demonstrated skill in handling complex tax issues, making them a trusted ally for individuals and businesses alike.

Why Bomar Law Firm Stands Out

The recognition from ThreeBestRated® is a testament to Bomar Law Firm's dedication to providing exceptional legal services. The firm specializes in a wide range of tax-related matters, including tax litigation, cryptocurrency tax planning, conservation easements, audit defense and IRS relief.  Their deep understanding of the U.S. tax system allows them to offer invaluable guidance to clients facing tax disputes. The firm's client-first approach and technical excellence set them apart in the ever-evolving world of tax law. 

Importance of the Award

Being awarded the ThreeBestRated® Business Excellence is significant for Bomar Law Firm as it reinforces their reputation for client satisfaction and knowledge. The platform, known for its rigorous 50-point inspection process, evaluates businesses based on reviews, reputation and customer satisfaction.  The firm's consistent recognition underscores their reliability and quality in the legal field. This accolade not only boosts their credibility but also assures clients of their ability to handle intricate tax issues effectively. For individuals and businesses in Georgia and as well as surrounding states, seeking legal help from a reputable firm can be crucial. Tax laws are complex and constantly changing, making it challenging to navigate without guidance. Tax attorneys at Bomar Law Firm stand ready to assist, offering unmatched legal representation and support to those in need. ]]> On Behalf of Bomar Law Firm <![CDATA[Understanding US Crypto Regulation: Three Key Bills on the Horizon]]> https://www.atlantataxattorney.com/?p=54410 2025-07-16T23:12:20Z 2025-07-16T23:02:04Z In a significant move for the cryptocurrency industry, the US House of Representatives is gearing up to vote on three key pieces of legislation this week. These bills aim to establish clearer rules for digital assets, potentially reshaping the crypto landscape in the United States.  The proposed crypto laws, known as the CLARITY Act, the Anti-CBDC Surveillance State Act, and the GENIUS Act, seek to address regulatory uncertainties and define the roles of various agencies in overseeing different types of tokens and are set to pass this week.

The Three Key Bills and Their Potential Impact

The CLARITY Act aims to create a regulatory framework for cryptocurrencies, potentially classifying many tokens as commodities rather than securities. This classification could significantly impact how crypto companies operate and are regulated.  The Anti-CBDC Surveillance State Act, as its name suggests, is designed to prevent the Federal Reserve from issuing a central bank digital currency (CBDC). This move reflects concerns about privacy and government control over digital money. Lastly, the GENIUS Act focuses on establishing rules for stablecoins, requiring issuers to back their tokens with liquid assets, such as US dollars, and disclose their reserves monthly. This transparency is intended to bolster trust in stablecoins, encouraging their use in mainstream financial systems.

What Is Happening So Far With The Bills?

At the beginning of the week, a group of House Republicans had blocked several cryptocurrency regulation bills from advancing, but after a meeting on Tuesday at the White House with President Donald Trump, they reportedly changed their minds and agreed to vote in favor of the legislation. Specifically, they agreed to support the GENIUS Act. This sudden reversal seemed to indicate that the bills would move forward, with Trump even taking to social media to announce the breakthrough. As of Wednesday, a new development has emerged in the cryptocurrency legislative landscape. A procedural vote to begin floor debate on the GENIUS Act has been delayed due to an internal conflict among Republicans. Some hard-line GOP members are demanding that the GENIUS Act be merged with the Anti-CBDC Surveillance State Act. While initial indications suggested GOP leadership was open to this, some conservatives have voiced opposition. Negotiations are currently underway to resolve this impasse.

Implications for the Crypto Market

If passed, these laws could have far-reaching effects on the cryptocurrency market. The regulatory clarity they provide might encourage more institutional investors to enter the crypto space, potentially leading to increased adoption and market growth. The stablecoin regulations, in particular, could enhance trust in these digital assets, which play a crucial role in crypto trading and transactions. However, the new regulations could also bring challenges for some crypto companies, especially those that have operated in regulatory gray areas. The classification of tokens as commodities or securities could impact how platforms offer these assets to customers and may require adjustments to current business models.  ]]> On Behalf of Bomar Law Firm <![CDATA[IRS conservation easement disputes: When to fight vs. settle]]> https://www.atlantataxattorney.com/?p=54404 2025-06-03T09:02:00Z 2025-06-03T09:02:00Z heightened federal scrutiny. You now face a tough decision: do you fight the IRS, or seek a settlement? This isn't only about your finances. The right choice could save you years of stress and worry. Your next crucial step is to carefully consider these factors.

Understanding your position

Before making any decisions, take stock of your position. Georgia's unique property valuation trends and conservation priorities create specific considerations for local investors. Review your conservation easement documentation, appraisals and substantiation. Strong, well-documented easements with legitimate conservation purposes and accurate valuations stand a better chance in disputes.

When to consider negotiating

Several factors might suggest that settlement is your best path forward. Consider these key indicators when evaluating your options:
  • Documentation weaknesses: Negotiation may be wise if your appraisal contains inconsistencies or your documentation is incomplete. The IRS typically has leverage when technical requirements aren't fully satisfied.
  • Cost-benefit analysis: Litigation is expensive and time-consuming. Sometimes, accepting a reasonable settlement saves more than you might win after years of legal fees and stress.
  • Partial validity: When some aspects of your easement are defensible while others are questionable, negotiation can preserve partial deductions rather than risking total disallowance.
These factors don't necessarily mean you’re surrendering. They simply suggest that compromise might protect your interests better than prolonged conflict.

When to stand your ground

In some situations, challenging the IRS position makes strategic sense. Here's when fighting might be your better option:
  • Strong technical compliance: Fighting may be worthwhile if your easement strictly adheres to IRS requirements with solid appraisals from qualified professionals.
  • Precedential value: Sometimes, your case may help establish favorable precedent for similar situations. This might justify litigation beyond your immediate financial interests.
  • Unreasonable IRS positions: When the IRS takes positions contrary to established law or makes demands that far exceed reasonable compromise, standing firm may be necessary.
Each of these scenarios requires careful evaluation by experienced counsel familiar with Georgia conservation practices and local IRS enforcement patterns.

The middle path: Partial settlements

Many successful resolutions involve partial settlements where some deductions are preserved while others are conceded. This approach often satisfies both the taxpayer's need for some benefit and the IRS's enforcement priorities.

Your next steps

Every conservation easement case is unique. Consulting with experienced tax counsel who focuses on conservation matters can provide clarity on your specific situation. Skilled legal guidance has helped numerous Georgia investors navigate IRS examinations, appeals and Tax Court litigation successfully. As a Georgia property investor, you're continuing a proud tradition of land conservation while making a sound financial decision. With proper guidance, you'll know when to stand firm and when compromise makes sense. Your initial goal of protecting our state's natural beauty deserves a thoughtful approach to these IRS challenges. That mission is worth defending, whatever obstacles you face.]]> On Behalf of Bomar Law Firm <![CDATA[Should I accept a Syndicated Conservation Easement audit settlement offer?]]> https://www.atlantataxattorney.com/?p=54260 2025-04-30T18:31:59Z 2025-04-30T18:31:59Z What should I know about IRS settlement offers? In an effort to help address what the IRS views as “abusive SCE transactions” in an efficient manner, the agency has sent out settlement offers to qualifying taxpayers. Only those who receive a letter are eligible. Taxpayers who are currently working on cases with the United States Tax Court are not eligible. Investors who receive an offer are wise to weigh the benefits and potential drawbacks. Carefully review the offer to understand the terms, including deadlines, financial implications, and future obligations. It is also helpful to consider alternative options. Explore other settlement options that may offer better outcomes but keep in mind the IRS continues to pursue enforcement actions related to SCEs.

Do I need legal counsel?

Coming to a decision on whether to accept the offer is not an easy one and the right answer varies depending on the details of the situation. A law firm with experience in this niche area of tax law can offer support and help guide you through the process. Benefits of legal counsel when navigating this decision can include:
  • Audit preparation and defense: Attorneys can help prepare for IRS audits by reviewing documentation, ensuring compliance, and defending the easement's validity.
  • Settlement negotiation: Legal counsel can assist in evaluating IRS settlement offers, advising on acceptance or negotiation strategies to minimize financial impact.
  • Criminal interview preparation: Though less common, criminal investigations can arise. Attorneys can prepare clients for interviews, ensuring they understand their rights and obligations.
  • Civil lawsuit tax relief: More frequently, investors face civil lawsuits. Legal counsel can guide them through the process, seeking tax relief and minimizing penalties.
SCE audits and settlements present significant challenges for investors. With the right legal support, navigating these complexities is more manageable. By understanding the current landscape and seeking experienced legal advice, investors can protect their interests and work towards a more favorable outcome.]]> On Behalf of Bomar Law Firm <![CDATA[Navigating the cryptic world of crypto taxes]]> https://www.atlantataxattorney.com/?p=54256 2025-04-25T03:12:22Z 2025-04-25T03:12:22Z Imagine you're in a maze, but instead of walls, you're surrounded by numbers, forms, and some very confusing tax laws. Welcome to the world of cryptocurrency taxation! As you zigzag through this financial labyrinth, remember that the IRS is watching, and they've got a new interest in your digital treasure trove. It's vital to get your ducks—or coins—in a row when tax season rolls around. From an Atlanta cryptocurrency attorney, here's everything you need to know.

Why you can't ignore crypto at tax time

Cryptocurrency might seem like a fun investment, like a digital game, but the IRS treats digital asset transactions the same traditional property transactions. Record everything. Every transaction, no matter how small, needs to be documented. Here are the details you need to keep track of:
  • Purchase and sales dates and amounts
  • Fair market values in USD at the time of the transaction
  • Detailed logs of trades and exchanges
Maintaining detailed records ensures you can substantiate your tax return claims, adhering to the Internal Revenue Code requirements.

Reporting crypto taxes

If you engage in transactions involving digital assets, it's mandatory to report them, regardless of whether they lead to capital gains or capital losses.

Gather your crypto tax documents

Before you sit down to crunch the numbers, make sure you have all your documents in hand:
  • Transaction histories: Download comprehensive logs from each exchange and wallet used.
  • Exchange statements: Collect all tax documents provided by cryptocurrency exchanges.
  • Payment records: If you've received cryptocurrencies as payment, note the market value at the time of receipt.
These documents are your first line of defense if the IRS knocks on your door.

Calculate gains and losses

This part can be tricky, but it's the crux of your crypto tax obligations:
  • Identify the type of asset: What exactly did you sell or trade?
  • Determine the basis: Understand the original value of your asset when acquired.
  • Calculate the gain or loss: Subtract the basis from the value at the time of sale or trade.
Knowing your gains and losses will guide you in filling out the right forms, like the 8949 and Schedule D.

Determine your basis

The next step in the process is determining the basis or the cost of your crypto assets. To do this, you'll need to know:
  • The type of digital asset acquired
  • When you acquired the digital asset, down to the time of day
  • How much of the asset you obtained
  • A fair market value at the time of acquisition
The IRS website has more information if needed.

Report using the appropriate form

The type of form required varies based on the transaction type:
  • Capital asset transactions: Use Form 8949 for sales, exchanges, or disposals of digital assets held as capital assets.
  • Ordinary income from digital assets: Report income from everyday activities on Form 1040 (Schedule 1).
  • Gifts of digital assets: Use Form 709 to report digital assets given as gifts.
  • Income for employees: Report wages received in digital assets on Form 1040 for employees.
  • Income for independent contractors: Use Schedule C (Form 1040) to report payments received in digital assets.
  • Business transactions: For digital asset transactions with customers, report on Schedule C (Form 1040).
Visit the IRS website for more details.

A tip for the future

Starting in January 2026, all cryptocurrency brokers will need to issue Form 1099-DA for the 2025 tax year. This will make your activities more transparent than ever and simplify the IRS's auditing process. Prepare now to avoid surprises later!

A crypto lawyer can help

Cryptocurrency taxes are undoubtedly complex, but with meticulous record-keeping and strategic planning, you can navigate this intricate landscape. Hiring a seasoned cryptocurrency lawyer might also be a wise move to avoid IRS issues. Remember, it's better to be safe than sorry when dealing with the IRS and your digital assets. Stay informed, stay compliant, and let your crypto journey be a tax-smart one.]]>