tax Advice Archive
“With every move he makes, another chance he takes”
June 23, 2021
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TweetShareSharePin0 Shares Today we have the pleasure of looking at an IRC 6751(b) opinion written by Judge Holmes. For long time readers of this blog, the link between Judge Holmes and Graev consequences of not following the statutory language requiring approval of the immediate supervisor are well known. His warning of Chai ghouls continues to
New portal for opting out of advance payments
June 22, 2021
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TweetShareSharePin0 Shares The IRS has opened an online site to enable taxpayers to unenroll from receiving advance payments of the 2021 child tax credit (CTC). The new “Child Tax Credit Update Portal” allows parents to view their eligibility, view their expected CTC advance payments, and, if they wish to do so, unenroll from receiving advance
Anti Injunction Act Bars Motion for Protective Order
June 22, 2021
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TweetShareSharePin0 Shares US v Meyer presents a somewhat unusual context for a court’s application of the Anti Injunction Act. Meyer stems from an injunction action due to allegations that Meyer promoted “an abusive tax scheme that result[ed] in scheme participants claiming unwarranted federal income tax deductions for bogus charitable contributions.” In 2018, the parties settled that
Getting Perspective on DAWSON
June 21, 2021
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Today guest blogger James Creech brings a series of articles to our attention which illuminate the Tax Court’s case management transition from a different point of view. Whatever your thoughts about DAWSON, considering the
A New Federal Holiday Give a New “Last Chance” For Some
June 18, 2021
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Today guest blogger Bryan Camp discuses the implications for tax procedure of the new federal holiday celebrating Juneteenth. National recognition of Juneteenth resulted from a years-long campaign by many including the incredible 94-year old
Supreme Court lets health care law stand
June 17, 2021
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TweetShareSharePin0 Shares The U.S. Supreme Court held on Thursday that several states and other plaintiffs that sued, asking the federal courts to declare unconstitutional the so-called individual mandate in the Patient Protection and Affordable Care Act (PPACA), P.L. 111-148, did not have standing to sue because they could not show that they had suffered or
Nuance in Determining the Taxpayers Last Known Address – Designated Orders, November 2, 2020
June 17, 2021
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TweetShareSharePin0 Shares There was only one designated order for the week of November 2, 2020 (Reddix-Smalls v. C.I.R., Dkt. # 17975-18L (docket with link here)). In it, Judge Gustafson ruled on whether a petitioner (allegedly) telling an Appeals Officer (AO) of a new address during a telephonic Collection Due Process hearing would legally change the
Can the Taxpayer Bill of Rights Assist in Overturning a Criminal Conviction?
June 16, 2021
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TweetShareSharePin0 Shares No. That’s the short answer. We have written before about ability, or lack of ability, of the Taxpayer Bill of Rights (TBOR) to protect someone from IRS action or inaction that the taxpayer views as a violation of TBOR here, here and here. I wrote a law review article on this subject you
Finality of a Tax Court Decision
June 15, 2021
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TweetShareSharePin0 Shares The Sixth Annual Tax Controversy Institute will be held online on Friday, July 16th, 2021. The virtual institute is sponsored by the University of San Diego School of Law and the tax law firm RJS Law. The event will be free of charge and will allow practitioners to earn free education credits. Speakers
Top tax cases practitioners should know
June 15, 2021
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TweetShareSharePin0 Shares Pinning down whether an activity is a trade or business for tax purposes, whether a tax penalty should be waived for reasonable cause, or the eternal question of when income is recognized for tax purposes — these issues arise often, and CPAs can benefit from being familiar with the judicial doctrines governing them.
