TweetShareSharePin0 Shares I wrote about documents bouncing back from the Tax Court last month in connection with the Tax Court policing the timely filing of petitions. The post caused commenter in chief Bob Kamman to pay careful attention to the orders coming out of the Tax Court and he noticed a particularly bad day for
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
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
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
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
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
TweetShareSharePin22 Shares With my colleague Marilyn Ames we are revising our subchapter on the Anti-Injunction Act in Chapter 1 of Saltzman and Book IRS Practice and Procedure to take into account last month’s CIC Services decision. Embedded in our discussion of the AIA is a discussion of its cousin, the Declaratory Judgment Act. Under the
Before the IRS can begin proceedings collections, taxes must be thoroughly assessed. However, the assessment date usually initiates the statute of limitations. This occurs mainly for the purpose of collection.
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.
TweetShareSharePin0 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