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tax Advice Archive

Timely TFRP Appeal?

TweetShareSharePin0 Shares The Tax Court only has jurisdiction in Trust Fund Recovery Penalty (TFRP) cases through Collection Due Process.  So, the TFRP jurisprudence in the Tax Court is rather slim.  Thanks to a tip from Bob Kamman, I learned of a case in which on January 14, 2022, Judge Gustafson issued an interesting 4-page order. 

IRS issues procedures for employee status determinations

TweetShareSharePin0 Shares The IRS issued procedural guidance Wednesday regarding determinations by the Service that a worker is properly classified as an employee of an employer rather than an independent contractor. The distinction carries significant employment law and tax ramifications. The latter include that a person for whom services are performed must withhold from employees’ wages

Refund Claims and Section 7508A

TweetShareSharePin0 Shares Bob Probasco, a regular guest poster, has joined Procedurally Taxing as a contributor. In today’s post, Bob unravels the intersection of the suspension rules of Section 7508A and the refund lookback limits in Section 6511. Les In normal years, the President may make multiple regional disaster declarations; in 2020, we had a nationwide disaster declaration related to

AICPA joins coalition seeking relief from IRS service challenges

TweetShareSharePin0 Shares As part of a diverse coalition of organizations representing tax professionals and other stakeholders — and in light of the continuing COVID-19 pandemic — the AICPA on Friday called on the IRS and Treasury to implement taxpayer relief from penalties and certain other compliance actions. The AICPA was among parties signing a letter

NTA Report Released: Essential Reading

TweetShareSharePin0 Shares Earlier this week the NTA released the 2021 Annual Report to Congress (link to full report). The report also includes as a separate volume the 2022 Purple Book, which lists 68 legislative recommendations that focus on ways to strengthen taxpayer rights and improve tax administration.  Both the Annual Report and the Purple Book

Tax Judgments and Quiet Titles

TweetShareSharePin0 Shares I have written before about the effect of the IRS obtaining a judgment with respect to a tax assessment.  In Boykin v. United States, No. 5:21-cv-00103 (W.D.N.C. 2022), the fact that the IRS had a judgment carries the day in a contest with a taxpayer involving a quiet title action.  The case provides

Tax Court Going Remote for the Remainder of January

TweetShareSharePin0 Shares In an announcement that did not surprise me, or maybe only surprised me in that I thought I might see it last week, the Tax Court has announced that it will go remote for the remainder of January.  This decision makes total sense given what is happening with the pandemic now and may
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