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aallenlenth Archive

Regs. on postponing tax deadlines due to federally declared disasters

TweetShareSharePin0 Shares In new final regulations (T.D. 9950), Treasury and the IRS have attempted to resolve ambiguities about when a federally declared disaster will lead to a mandatory 60-day postponement of certain time-sensitive tax-related deadlines. The final regulations adopt, with some changes, proposed regulations issued in January (REG-115057-20). The mandatory postponement provision, Sec. 7508A(d), was

Technology and Taxpayer Rights

TweetShareSharePin0 Shares This post includes information about the IRS’s plans to use AI to assist taxpayers. For more insight on the legal risks tax administrations face from using AI-enabled systems, including risks to taxpayer rights, there is a Zoom lecture hosted by Antwerp and VIA Universities, HMRC, the Prosperity Collaborative, and the Center for Taxpayer

More On The Implications of CIC Services

TweetShareSharePin0 Shares We are starting to see some fallout from last month’s CIC Services opinion. For example, Tax Notes’ Kristen Parillo discusses[$] Hancock Land Acquisitions v US , another microcaptive case. Parillo’s article explores the parties’ post CIC Services supplemental filings in a case where the taxpayer brought an action alleging that the IRS’s failure to refer its case

US IRS Flags Deadline For Q2 Estimated Tax Payments

TweetShareSharePin0 Shares by Mike Godfrey, Tax-News.com, Washington 09 June 2021 The US Internal Revenue Service has issued a reminder to taxpayers who pay estimated taxes that they have until June 15 to pay their estimated tax payment for the second quarter of tax year 2021 without incurring a penalty. Estimated tax is the method

Limitation on Issues Taxpayer Can Raise in Passport Case

TweetShareSharePin0 Shares The case of Shitrit v. Commissioner, T.C. Memo 2021-63 points out the limitations on raising issues other than the revocation of the passport when coming into the Tax Court under the jurisdiction of the passport provision.  Petitioner here tries to persuade the Tax Court to order the issuance of a refund but gets

Need to File Back Taxes?

You should ensure that you file now to avoid penalties and interest. When you file now, you'll be able to pay with the least amount of applied charges. Additionally, all late payments are also factored into the total that you'll pay when you file now.

IRC 7459(d) and the Impact of Dismissal

TweetShareSharePin11 Shares On May 20, 2021, the Court of Federal Claims decided the case of Jolly v. United States, Dk. No. 20-412.  Ms. Jolly pursued the case pro se.  The court lists the opinion as not for publication. The case involves a refund suit covering four tax years.  The court decided not to dismiss her

DAWSON Update and Example of Tax Court Policing

TweetShareSharePin0 Shares Carl Smith continues to probe the Tax Court docket sheet as he has done for many years but in his retired retirement, he finds working his way through DAWSON interesting as new features arrive unexpectedly to be discovered.  The latest new feature Carl has found is one about which those of us who
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