information Archive
No Reasonable Cause For Failing To Include $238,000 From Information Return Sent To Old Address
July 18, 2022
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TweetShareSharePin0 Shares Back in 2013, I wrote about Andersen v Comm’r, a summary opinion where a taxpayer failed to include $28,000 of W-2 income but was not subject to a 20% civil penalty for substantially understating income. In Andersen, the Tax Court held that there was reasonable cause for the omission and the taxpayer acted
Prior Opportunity and Other Collection Due Process Information
June 1, 2022
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TweetShareSharePin0 Shares At the Court Practice and Procedure committee during recent ABA Tax Section meeting there was a panel on Collection Due Process (CDP.) The panel put up some statistics on CDP from a few years ago that I will put into this post. It also discussed a 15 year old case precedential CDP case,
Information on Appeals Presented at ABA Tax Section Meeting
May 27, 2022
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TweetShareSharePin0 Shares During the Administrative Practice Committee meeting a panel occurred regarding Appeals and the impact of COVID. The panel offered a couple slides about Appeals inventory that might be of value to readers interested in what’s happening in Appeals. The panel also discussed some issues regarding Appeals inventory and case handling. The first slide
Information from Court Practice and Procedure Programming at ABA Tax Section Meeting Part 2
May 26, 2022
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TweetShareSharePin0 Shares In this post I will highlight the slides presented by Mark Cottrell, Branch 6 Chief, IRS (Procedure & Administration) during the committee program as well as some of his other remarks. The slides give a good view of the case statistics for the recent period. The first slide shows tax dollars in dispute
Information from Court Practice and Procedure Programming at ABA Tax Section Meeting Part 1
May 25, 2022
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TweetShareSharePin0 Shares This committee put on a panel including representatives from the Tax Court, the Court of Federal Claims, the Tax Division of the Department of Justice and the Procedure and Administration Division of Chief Counsel (P&A). I took notes while they were speaking and provide you here with what I found important from the
Can Intentionally Filing an Improper Information Return Justify a Claim for Damages Under Section 7434?…Continued!
May 19, 2022
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TweetShareSharePin0 Shares We welcome back guest blogger Omeed Firouzi, who works as a staff attorney at the Taxpayer Support Clinic at Philadelphia Legal Assistance, for a discussion of the latest case involving an information return with improper information. The question of how far the statute goes in order to protect recipients continues to play out

IRS blames old tech in destruction of information returns
May 16, 2022
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TweetShareSharePin0 Shares The IRS said Thursday that it destroyed approximately 30 million unprocessed information returns because its “antiquated technology” forced it to dispose of the paper documents and vowed to process all such information returns that it received in 2021 and 2022. The IRS statement was in response to an audit report by the Treasury
IRC § 7602(e) Will Not Save You (From Bank Information Return Exams)
October 26, 2021
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TweetShareSharePin0 Shares Lately there has been much fury and gnashing of teeth on the Biden administration proposal to vastly increase bank reporting requirements to the IRS. In a nutshell, the proposal would require banks and credit unions to send information returns to the IRS wherever an individual hits a threshold amount of “inflows and outflows”
EU To Table A Digital Tax Proposal In October
September 15, 2021
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TweetShareSharePin0 Shares by Ulrika Lomas, Tax-News.com, Brussels 15 September 2021 The European Commission has committed to tabling a proposal for a digital tax in October, whether or not an international agreement surfaces from OECD-led talks on new international tax rules for the world’s largest firms. The pledge was made after members of the European Parliament
US Lawmakers Approve New Cryptoassets Reporting Rules
August 25, 2021
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TweetShareSharePin0 Shares by Mike Godfrey, Tax-News.com, Washington 25 August 2021 The US Senate has approved the inclusion of new provisions in the bipartisan infrastructure bill to require intermediaries involved in cryptocurrency trading to report details about transactions.
Despite concerns raised by various lawmakers that the provisions fail to provide clarity about who the reporting