tax Advice Archive

TweetShareSharePin0 Shares In Johnson v. United States, No. 2:19-cv-01561 (E.D. Cal. 2021) the district court finds that taxpayers’ correspondence with the case advocate in the Local Taxpayer Advocate’s (LTA) office provided a sufficient basis for determining that an informal claim existed.  The taxpayers sought to have the correspondence serve as an informal claim for both

TweetShareSharePin0 Shares The IRS has recently made some updates to the format of transcripts.  The National Taxpayer Advocate describes the updates in a two part blog series you can find here and here.  If you have been wondering why the transcript appearance you have grown accustomed to viewing is different, read the posts to gain

TweetShareSharePin0 Shares 0 Flares Filament.io Made with Flare More Info“> 0 Flares × The Sixth International Taxpayer Rights Conference kicked off today with a workshop on ombuds and advocates and continues through Friday. As Nina Olson mentioned last week in Taxpayer Rights as Human Rights: Registration is

TweetShareSharePin0 Shares I am confused by the court’s introduction of the case which indicates that the IRS brought suit to hold Stanley Craft liable as a responsible officer.  Usually, the IRS assesses the Trust Fund Recovery Penalty (TFRP) and the responsible person brings a refund suit against the United States seeking to recover any amount

TweetShareSharePin0 Shares This is an exciting development for those interested in tax procedure. We have discussed Boechler and the question of jurisdictional time limits often on Procedurally Taxing. Carl Smith blogged about the Eighth Circuit decision here. Carl explained, In Boechler, P.C. v. Commissioner, 2020 U.S. App. LEXIS 23306, on July 24, [2020], the Eighth Circuit

TweetShareSharePin0 Shares Quintela Group, LLC v. United States, No. 4:20-cv-03499 (S.D. Tex. 2021) provides insight both into the objection by the IRS to confirmation of a plan of reorganization and the objection by IRS counsel, presumably an assistant U.S. Attorney, to questions posed during the confirmation hearing.  Both objections provide the opportunity for discussion.  We

TweetShareSharePin0 Shares News ESTATES, TRUSTS & GIFTS By Paul Bonner The IRS issued final regulations Monday (T.D. 9957) instituting a user fee of $67 for the Service to issue an estate tax closing letter. The final regulations adopt without significant change proposed regulations issued in late December 2020 (REG-114615-16). An estate tax closing letter