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tax Advice Archive

Limitation on Issues Taxpayer Can Raise in Passport Case

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

IRC 7459(d) and the Impact of Dismissal

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  The court lists the opinion as not for publication.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

DAWSON Update and Example of Tax Court Policing

TweetShareSharePin0 Shares Carl Smith continues to probe the Tax Court docket sheet as he has done for many years but in his retired retirement, he finds working his way through DAWSON interesting as new features arrive unexpectedly to be discovered.  The latest new feature Carl has found is one about which those of us who

TIGTA Releases Report on Improper Payment Rate For Refundable Credits

TweetShareSharePin0 Shares Last month TIGTA released its annual review of the IRS’s improper payment reporting requirements under the Payment Integrity Information Act  (PIIA). The focus in this TIGTA report is the IRS’s administration of refundable credits. In the pre-COVID time frame (FY 20), OMB determined that the Earned Income Tax Credit (EITC), Additional Child Tax Credit (ACTC), and American Opportunity

President’s budget contains many tax proposals

TweetShareSharePin0 Shares President Joe Biden’s administration unveiled its proposed budget for fiscal year 2022 on Friday. Treasury says the $6 trillion proposed budget focuses on infrastructure, clean energy, and research and development, and among its many provisions are a host of proposed tax changes affecting individuals and corporations. One set of tax and revenue proposals,

Follow Up Information on Tax Court Service of Petitions

TweetShareSharePin0 Shares Yesterday, we published some data from Carl Smith showing that the service of a new Tax Court petition on the office of Chief Counsel was taking about two months.  Following that observation, Carl did some additional digging and found the service time to vary considerably.  Below is a chart of his most recent

Draft employer’s payroll tax return incorporates ARPA changes

TweetShareSharePin0 Shares The IRS on Tuesday released a draft revised 2021 version of Form 941, Employer’s Quarterly Federal Tax Return, reflecting further new and updated payroll tax credits. The current official version was released less than three months earlier on March 9, and the impending further changes reflect Congress’s multiple provisions of temporary payroll tax

Things That Make You Say Hmmm

TweetShareSharePin0 Shares We welcome back guest blogger and commenter in chief, Bob Kamman.  As usual, Bob has found things that the rest of us overlook.  In addition to the interesting twists on the way things work that Bob discusses below, I received a message from Carl Smith who, though retired, still takes some interest in
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