tax Advice Archive

TweetShareSharePin0 Shares IRS examinations of partnerships under the procedures of the Bipartisan Budget Act (BBA) of 2015, P.L. 114-74, more often ended with no additional tax liability proposed than for all partnership audits of returns for the same tax years, the Treasury Inspector General for Tax Administration (TIGTA) reported in an audit (Rep’t No. 2022-30-020).

TweetShareSharePin0 Shares In the first year of this blog, I wrote a post on the case of Anderson v. Commissioner, 2013-261, questioning why the Settlement Officer (SO) in Appeals did not reject a taxpayer’s offer by citing public policy grounds.  In that case the Tax Court remanded a Collection Due Process (CDP) determination because the

TweetShareSharePin0 Shares The IRS released proposed regulations Friday (REG-121508-18) providing an exception from the “unified plan rule” for multiple-employer plans when one or more participating employers in the plan fail to take required actions. The regulations also would update a number of other provisions to reflect changes since the IRS last issued final regulations for

TweetShareSharePin0 Shares 0 Flares Filament.io Made with Flare More Info“> 0 Flares × On March 23, 2022, the Tax Court announced proposed amendments to its Rules.  The proposal is quite lengthy but a large part of the amendments seeks to clean up language or more closely conform

TweetShareSharePin0 Shares Last April, I wrote (see here and here and here) about the Federal Circuit’s decision in General Mills, Inc. v. United States, 957 F.3d 1275 (Fed. Cir. 2020), aff’g 123 Fed. Cl. 576 (2015).  The briefs on appeal are available here: the taxpayer’s opening brief, the government’s answering brief, and the taxpayer’s reply

TweetShareSharePin0 Shares While the pandemic and law changes were primarily responsible for the IRS’s inability to meet timeliness standards for the majority of taxpayers’ cases last year, inefficiencies in staffing, equipment, and procedures also contributed to the lag, the Treasury Inspector General for Tax Administration (TIGTA) said in an audit report. The report, titled Program

TweetShareSharePin0 Shares The IRS highlighted in a news release that all filers of Forms 1040, U.S. Individual Income Tax Return, 1040-SR, U.S. Tax Return for Seniors, and 1040-NR, U.S. Nonresident Alien Income Tax Return, must answer the forms’ question regarding virtual currency. The question, which on Form 1040 is just below the address block, asks,