tax Advice Archive

TweetShareSharePin0 Shares Bob Probasco picks up from his post last week and continues discussing the tricky issue of when interest starts to accrue on refunds when the taxpayer may not have known that they had a return filing obligation on the due date of the return. Les And now some observations and questions about that

TweetShareSharePin0 Shares Today guest poster Bob Probasco walks us through the case law and recent IRS memo addressing a foreign corporation which files a return after a normal due date because it only later realizes it has a filing obligation. The issue is one I recently discussed but in today’s first of two parts Bob

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

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

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

TweetShareSharePin0 Shares November 25, 2021 by Stephen Olsen Leave a Comment 0 Flares Filament.io 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

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.