tax Advice Archive
Online sign-up now available for advance child tax credit payments
June 14, 2021
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TweetShareSharePin0 Shares The IRS opened an online site Monday that allows taxpayers who are not required to file a 2019 or 2020 individual income tax return to sign up to receive advance child tax credit (advance CTC) payments, which will begin July 15 (see IRS News Release IR-2021-129). The “Child Tax Credit Non-Filer Sign-Up Tool”
Pro Publica Tax Dump
June 14, 2021
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Our post today features an Op Ed that Les wrote reacting to the Pro Publica release of information. Because Les is on vacation, I have the opportunity to introduce his post which he asked
IRS posts ARPA credit FAQs
June 11, 2021
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TweetShareSharePin0 Shares The IRS posted two sets of FAQs to its website on Friday, explaining changes to various credits made by the American Rescue Plan Act (ARPA), P.L. 117-2. New Child and Dependent Care Tax Credit FAQs discuss changes made by ARPA that increased the maximum amount of work-related expenses for qualifying care that may
Bouncing Documents at the Tax Court
June 11, 2021
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TweetShareSharePin0 Shares I wrote about documents bouncing back from the Tax Court last month in connection with the Tax Court policing the timely filing of petitions. The post caused commenter in chief Bob Kamman to pay careful attention to the orders coming out of the Tax Court and he noticed a particularly bad day for
Regs. on postponing tax deadlines due to federally declared disasters
June 10, 2021
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TweetShareSharePin0 Shares In new final regulations (T.D. 9950), Treasury and the IRS have attempted to resolve ambiguities about when a federally declared disaster will lead to a mandatory 60-day postponement of certain time-sensitive tax-related deadlines. The final regulations adopt, with some changes, proposed regulations issued in January (REG-115057-20). The mandatory postponement provision, Sec. 7508A(d), was
Technology and Taxpayer Rights
June 10, 2021
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TweetShareSharePin0 Shares This post includes information about the IRS’s plans to use AI to assist taxpayers. For more insight on the legal risks tax administrations face from using AI-enabled systems, including risks to taxpayer rights, there is a Zoom lecture hosted by Antwerp and VIA Universities, HMRC, the Prosperity Collaborative, and the Center for Taxpayer
More On The Implications of CIC Services
June 9, 2021
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TweetShareSharePin0 Shares We are starting to see some fallout from last month’s CIC Services opinion. For example, Tax Notes’ Kristen Parillo discusses[$] Hancock Land Acquisitions v US , another microcaptive case. Parillo’s article explores the parties’ post CIC Services supplemental filings in a case where the taxpayer brought an action alleging that the IRS’s failure to refer its case
Limitation on Issues Taxpayer Can Raise in Passport Case
June 8, 2021
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TweetShareSharePin0 Shares The case of Shitrit v. Commissioner, T.C. Memo 2021-63 points out the limitations on raising issues other than the revocation of the passport when coming into the Tax Court under the jurisdiction of the passport provision. Petitioner here tries to persuade the Tax Court to order the issuance of a refund but gets
In Gilbert v US Ninth Circuit Weighs in on The Declaratory Judgment Act
June 7, 2021
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TweetShareSharePin22 Shares With my colleague Marilyn Ames we are revising our subchapter on the Anti-Injunction Act in Chapter 1 of Saltzman and Book IRS Practice and Procedure to take into account last month’s CIC Services decision. Embedded in our discussion of the AIA is a discussion of its cousin, the Declaratory Judgment Act. Under the
IRC 7459(d) and the Impact of Dismissal
June 4, 2021
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TweetShareSharePin11 Shares On May 20, 2021, the Court of Federal Claims decided the case of Jolly v. United States, Dk. No. 20-412. Ms. Jolly pursued the case pro se. The court lists the opinion as not for publication. The case involves a refund suit covering four tax years. The court decided not to dismiss her