Menu

tax Advice Archive

Informal Refund Claim Allowed

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

Transcript Updates

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

Refining the Tax Court’s Jurisdiction in Passport Cases

TweetShareSharePin0 Shares The case of Garcia v. Commissioner, 157 T.C. No. 1 (2021) provides clarity and guidance on the Tax Court’s jurisdiction in passport cases as the Court issues a precedential opinion to make clear some of the things that can and cannot happen in a contest regarding the certification of passport revocation.  I did

Appeals Finalizes Team Case Leader Initiative

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

Effective Tax Administration and Equitable Estoppel as Defenses to Assessment of Trust Fund Recovery Penalty

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

Supreme Court Agrees to Decide Whether the CDP Petition Filing Deadline Is Jurisdictional

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

Objecting to Chapter 11 Plan/Objecting to Judge’s Questions

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

Can IRS Levy Reach Future Rent Payments?

TweetShareSharePin0 Shares A relatively brief CCA issued this month discusses the IRS’s ability to levy on the right to receive rent payments beyond the date of the levy. The CCA explores the rationale as to why a single levy may have continuous legal effect that will extent to the right to receive future payments, a
You cannot copy content of this page
Social Media Auto Publish Powered By : XYZScripts.com