tax Advice Archive
APA and FBAR Skirmishes Continue in Schwarzbaum v US
April 13, 2022
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TweetShareSharePin0 Shares A couple of months ago in 11th Circuit Remands Willful FBAR Penalty Case Back to IRS Due to APA Violation I blogged about Schwarzbaum v United States, where the Eleventh Circuit held that Schwarzbaum willfully violated his FBAR reporting obligations for three years but that the IRS miscalculated the FBAR penalties. As I discussed,

Letters from IRS to warn taxpayers about possible QOF actions needed
April 12, 2022
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TweetShareSharePin0 Shares Taxpayers who may need to take additional actions related to qualified opportunity funds (QOFs) should begin receiving letters in the mail in April. the IRS announced Tuesday. The IRS said it will begin sending letters this month to taxpayers, including corporations or partnerships organized as a QOF, whose Form 8996, Qualified Opportunity Fund,

Acute IRS challenges had chronic origins, GAO reports
April 12, 2022
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TweetShareSharePin0 Shares The 2021 tax filing season featured IRS administrative challenges that were unprecedented in scope but long-standing in their causes, the U.S. Government Accountability Office (GAO) said in a report released Monday. And while the issues uncovered in the GAO’s study mostly stemmed from the COVID-19 pandemic’s continuing effects, they are likely to persist
GAO Assesses IRS 2021 Filing Season Progress
April 12, 2022
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It is a busy couple of weeks for blogging crew. For those wanting a fix of tax administrative news pending our next substantive post, we recommend taking a look at the GAO report 2021
Principal Residences as Collection Target: TIGTA Criticizes IRS Practice
April 11, 2022
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TweetShareSharePin0 Shares In The IRS Primarily Uses Lien Foreclosures When Pursuing Principal Residences, Which Do Not Provide the Same Legal Protections as the Seizure Process TIGTA released a report detailing how IRS uses judicial lien foreclosure suits rather than administrative collection tools when it targets a taxpayer’s principal residence to satisfy an assessed liability. The

NTA calls for more time to contest denial of refund or credit claim
April 8, 2022
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TweetShareSharePin0 Shares National Taxpayer Advocate (NTA) Erin Collins recommended that the IRS temporarily postpone the two-year time limit for taxpayers to file a lawsuit to contest the Service’s disallowance of a claim for refund or credit and allow more time to resolve such disputes administratively with the IRS. Collins included the recommendation in her NTA

IRS commissioner to senators: ‘Our efforts are working’
April 8, 2022
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TweetShareSharePin0 Shares IRS Commissioner Charles Rettig updated members of the Senate Finance Committee Thursday on the Service’s performance in the soon-to-be-concluded tax filing season, as well as longer-term assessments of its efforts to modernize its operations, fill staffing gaps, and improve taxpayer service and enforcement. Asked repeatedly by senators about the IRS’s much-publicized backlog of

IRS eases application process for US residency certification
April 5, 2022
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TweetShareSharePin0 Shares The IRS temporarily revised its procedures effective Monday for some submitters of Form 8802, Application for United States Residency Certification, to facilitate applications where the Service has not yet completed its processing of the applicant’s most recently filed tax return. The new policy, announced on the IRS’s website, applies to applicants whom the

Proposed regulations revise premium tax credit’s affordability test
April 5, 2022
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TweetShareSharePin0 Shares The IRS issued proposed regulations Tuesday (REG-114339-21) that would reinterpret how affordability of employer health care coverage is determined for purposes of a premium tax credit (PTC) with respect to family members of an employee to whom the coverage is offered. Under the current regulations adopted as final in 2013, the approach to
Partial Pay Installment Agreements In the Dark
April 5, 2022
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TweetShareSharePin0 Shares A recent TIGTA report highlights the redheaded stepchild of collection alternatives, partial pay installment agreements (PPIAs). The report highlights how relatively infrequently taxpayers enter into PPIAs and reveals how a lack of outward facing information about PPIAs contributes to their low use and jeopardizes taxpayer rights. The TIGTA report’s use of a taxpayer