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tax Advice Archive

Tolling the Statute of Limitations by Filing Bankruptcy

TweetShareSharePin0 Shares The case of Lufkin v. Commissioner, T.C. Memo 2021-71, puts the Tax Court in a position to rule on the impact of filing bankruptcy on the statute of limitations.  The taxpayers raise arguments not only regarding the collection statute of limitations but also the validity of the underlying assessment, which gives me the

Math Error

TweetShareSharePin0 Shares We have written before about Math Error here, here, here and here.  Last week, the National Taxpayer Advocate (NTA) wrote a very nice blog post explaining math error but also providing some surprising details on the volume of math error notices sent out during the past filing season.  This is the first of

Nominees

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.

Jurisdiction to Hear Naked Owners’ Wrongful Levy Suit Hinges on State Property Law

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

Tax Court Announcement re Premature Assessments

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.

COBRA premium assistance credit clarified further

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

Unsigned and Electronically Signed Refund Claims

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
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