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tax Advice Archive

IRS Releases Update on Frequently Asked Questions Part 2

TweetShareSharePin0 Shares Today guest blogger James Creech brings us his take on the recent IRS news release and fact sheet announcing important changes in the agency’s use of frequently asked questions. Part One in this series can be found here. Christine As an extended filing day surprise the IRS has released a news release on the role Frequently

IRS Releases Update on Frequently Asked Questions Part 1

TweetShareSharePin0 Shares Last week the IRS issued a news release and fact sheet discussing its use of frequently asked questions. The IRS’s practice of using FAQs has been the subject of many Procedurally Taxing blog posts. This week we will run a series with different practitioners offering their perspective on the development. Today, we hear

Videoconferencing with IRS now an option for all LB&I taxpayers

TweetShareSharePin0 Shares News PROCEDURE & ADMINISTRATION By Paul Bonner All large business taxpayers and their representatives may meet with IRS officials by videoconference upon request, the Service told its employees in the Large Business and International (LB&I) Division in a memo. The memo, LB&I-04-0821-0011, dated Sept. 3, is effective Monday, when it was publicly

IRS Violates Taxpayer Bill of Rights by Unilaterally Terminating Installment Agreements Entered into with Private Collection Agencies

TweetShareSharePin0 Shares I have written extensively about the IRS use of private debt collectors.  You can read a few highlights here and here and here.  By way of background, IRC § 6306 requires the IRS to “enter into one or more qualified collection contracts for the collection of all outstanding inactive tax receivables.”   An “inactive

Third Time is the Charm for CDP Case

TweetShareSharePin0 Shares In Dodd v. Commissioner, T.C. Memo 2021-118, the Tax Court decides the merits of petitioner’s case, having twice remanded the case previously.  In the end, Ms. Dodd lost the merits of her case and owes a large tax liability.  The case shows what happens when the IRS fails to properly conduct the Collection

SSA provides 2022 tax wage base, benefit COLA

TweetShareSharePin0 Shares The maximum amount of an individual’s taxable earnings in 2022 subject to Social Security tax will be $147,000, the Social Security Administration (SSA) announced Wednesday. An increase from $142,800 for 2021, the wage base limit applies to earnings subject to the tax, known officially as the old age, survivors, and disability insurance (OASDI) tax.

Failure to Timely Raise Financial Disability Argument

TweetShareSharePin0 Shares We have written on several occasions about the exception to the two and three-year lookback periods of IRC 6511 that exist as a possibility if the taxpayer can show financial disability.  You can find posts on the subject here, here and here.  This year my clinic represented someone making the financial disability argument

In Summons Dispute IRS Entitled to Confidential Emails Between Insurance Companies and State Regulator

TweetShareSharePin0 Shares In US v Delaware Department of Insurance a federal district court ordered the Delaware Department of Insurance (DDOI) to turn over emails associated with micro-captive promoters.  In tax cases it is somewhat unusual that the federal government finds itself in court with state attorneys as adversaries. The case flags tension between the vast
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