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tax Advice Archive

IRS launches ‘Tax Pro Account’ feature

TweetShareSharePin0 Shares The IRS unveiled a new online feature on Monday known as the “Tax Pro Account,” the purpose of which, for now, is to automate the submission of powers of attorney (POAs) to authorize tax practitioners to represent individual taxpayers and tax information authorizations (TIAs) to view their taxpayers’ accounts. But the IRS ultimately

IRS Wins Lien Priority Fight with Bank

TweetShareSharePin0 Shares In Citizens Bank, N.A. v. Nash, No. 2:20-cv-00351 (E.D. Pa. 2021) a lien priority fight occurred between the IRS and the bank holding the taxpayer’s mortgage.  In many ways the bank’s problem reminded me of problems that routinely plague the IRS in lien priority fights.  The bank erroneously recorded a release and that

Incarcerated Individual Subject to Delinquency Penalties Even Though Attorney Embezzled Funds and Failed To File His Tax Returns

TweetShareSharePin0 Shares We have often discussed the reach of the 1985 Supreme Court case United States v. Boyle. Section 6651(a)(1) and (2) impose delinquency penalties for failing to file a tax return or pay a tax unless the taxpayer can establish that the failure was due to reasonable cause and not willful neglect.  Boyle essentially stands for

IRS Taking Payments Beyond Ten Years of Assessment Still Timely

TweetShareSharePin0 Shares Dean v US involves a motion to dismiss a taxpayer’s suit alleging that the IRS recklessly disregarded the law by continuing to levy on a taxpayer’s Social Security payments beyond the ten year SOL on collections.  The magistrate concluded that the IRS’s actions were not improper and recommended that the case be dismissed. The

How Tax Regulations Are Made

TweetShareSharePin0 Shares Today’s post is by frequent guest poster Monte Jackel, Of Counsel at Leo Berwick. In today’s post, Monte discusses his reactions to an article written by Shu-Yi Oei of Boston College Law School and Leigh Osofsky of the University of North Carolina at Chapel Hill. A few years ago they wrote an insightful article on the process that led to
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