TAX RESOLUTION Archive
TweetShareSharePin0 Shares Several years ago I wrote a post providing a general explanation of nominee liens in discussing two decisions. Christine wrote an excellent post on a case that had an income tax twist to the nominee situation, but she also expanded my discussion of the nominee lien doctrine. The case of United States v.
TweetShareSharePin0 Shares We welcome back guest blogger Matthew Hutchens of the University of Illinois Gies College of Business. With co-author Erin Stearns, Hutch recently updated the lien and levy chapters of Effectively Representing Your Client Before the IRS. In today’s post, he examines a recent Fifth Circuit opinion in which niche questions of Louisiana law
TweetShareSharePin11 Shares The Tax Court has finally publicly acknowledged the problem it is having processing new petitions. On Friday, July 23, 2021, it issued the following notice: The United States Tax Court has received a significantly higher number of petitions this year. The total number filed in a typical year is between 23,000 and 26,000.
TweetShareSharePin0 Shares News EMPLOYEE BENEFITS & PENSIONS By Dave Strausfeld, J.D. In 11 questions and answers, the IRS on Monday gave additional guidance to employers, health insurers, and plan administrators on how to provide laid-off employees temporary assistance paying for COBRA continuation coverage and claim a corresponding tax credit (Notice 2021-46). In May, the
TweetShareSharePin0 Shares What happens if a taxpayer timely files a refund claim, IRS denies the claim because it mistakenly believes that the claim is untimely and the taxpayer fails to files a refund suit within two years? To top it off, IRS, outside the two-year window for filing suit, realizes that it made an initial
TweetShareSharePin0 Shares Last year I blogged on the case of Gregory v. United States, 149 Fed. Cl. 719 (2020), in which the Court of Federal Claims denied a refund claim because the taxpayers did not sign the amended return. It turns out the Gregory case is part of a larger group of cases involving the
TweetShareSharePin0 Shares As the name and its suggests, the Taxpayer First Act (TFA) made numerous changes to the tax code with the general intent of improving taxpayer rights and interaction with the IRS. These changes ranged from the possibly consequential (Sec. 1101’s requirement that the IRS submit a comprehensive customer service strategy to Congress, found
TweetShareSharePin0 Shares When Bryan was writing his post, we had an exchange about OICs. Some of the comments I provided to him I might have provided in posts over the years, but I will state them here in case we have new readers or old readers with memories like mine. Most of these comments relate
TweetShareSharePin0 Shares The case of Mason v. Commissioner, T.C.M. 2021-64 shows at least one benefit of submitting an offer in compromise (OIC) through a request for a collection due process (CDP) hearing. As part of his lessons from the Tax Court series, Bryan Camp has written an excellent post both on the case and the
TweetShareSharePin0 Shares The IRS unveiled a new online feature on Monday known as the “Tax Pro Account,” the purpose of which, for now, is to automate the submission of powers of attorney (POAs) to authorize tax practitioners to represent individual taxpayers and tax information authorizations (TIAs) to view their taxpayers’ accounts. But the IRS ultimately