tax Advice Archive

E-signing for forms, tax compliance documents extended

TweetShareSharePin0 Shares In a pair of internal memos (NHQ-10-1121-0005 and NHQ-01-1121-0004), the IRS has extended until Oct. 31, 2023, procedures that allow taxpayers and their representatives to sign digitally or by an image of their signatures an array of forms and returns as well as certain compliance-interaction-related forms and documents. The memos also reapprove for

Throwing the Baby Out with the Bathwater – the Proposed Repeal of IRC § 6751(b) Supervisor Approval of Penalties

TweetShareSharePin0 Shares Avid readers of Procedurally Taxing know that we have been closely following the litigation over IRC § 6751(b) and the Graev line of cases.  This litigation has also received attention from Congress in the Build Back Better Act, H.R. 5376, in which § 138404 repeals this provision and replaces it with a toothless

Join the Annual PT Giving Tuesday Drive

TweetShareSharePin0 Shares 0 Flares Made with Flare More Info“> 0 Flares × It’s that time of year for the annual Procedurally Taxing tradition (among other traditions such as April Fool’s, Taxatturkeys, etc.) in which we provide an update on the Center for Taxpayer Rights’ activities over

Overpayment, or Not?

TweetShareSharePin0 Shares We welcome back guest blogger Bob Probasco. Today Bob untangles the issue of deposits versus payments in relation to stipulated decision documents filed with the Tax Court. The character of the taxpayer’s remittance matters here, as it determines whether they are entitled to overpayment interest. For those looking to make a deposit rather

Happy Thanksgiving Taxatturkeys

TweetShareSharePin0 Shares November 25, 2021 by Stephen Olsen Leave a Comment 0 Flares Made with Flare More Info“> 0 Flares × Related About Stephen Olsen Stephen J. Olsen’s practice includes tax planning and controversy matters for individuals, businesses and exempt entities for the law firm Gawthrop

New R&D credit documentation applies to amended returns

TweetShareSharePin0 Shares A recent IRS legal memo specifying information that taxpayers must provide starting early next year in a claim for refund for a tax credit under Sec. 41 for increasing research activities (research and development, or R&D credit) applies to claims on amended returns only, said Holly Paz, deputy commissioner of the IRS Large

Depositions in Tax Court

TweetShareSharePin0 Shares Unlike in district court where depositions play an integral role in litigation, depositions in Tax Court occur with much less frequency.  The Tax Court recently issued an order allowing the IRS to take the depositions of two witnesses via Zoom in the case of Oconee Landing Property, LLC et al v. Commissioner, Dk.
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