tax Advice Archive

BBA partnership audits show high no-change rate, TIGTA says

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).

Various exempt organization notices paused

TweetShareSharePin0 Shares The IRS said Friday it is suspending its issuance of 10 notices generally sent to tax-exempt organizations about late return filings. The IRS listed the paused notices in its periodic Exempt Organization Update newsletter for charities and not-for-profit organizations. Like its suspension earlier of a broader range of notices and letters to other

IRS reproposes unified plan rule exception for multiple-employer plans

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

Tax Court Proposed Rule Changes

TweetShareSharePin0 Shares 0 Flares 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

Is Supreme Court Review Possible?

TweetShareSharePin0 Shares The last time we talked about Goldring v. United States, 15 F.4th 639 (5th Cir. Oct. 4, 2021), the taxpayers had won their case for a refund of deficiency interest, creating a circuit split with FleetBoston Fin. Corp v. United States, 483 F.3d 1345 (Fed. Cir. 2007).  On November 18th, the government petitioned

You Call That “Notice”? Seriously?

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

TIGTA: IRS inefficiencies worsened backlog

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

Confusion Over Attorney’s Fees in Ninth Circuit Stems from Statute and Regulation…

TweetShareSharePin0 Shares Today we welcome back Maria Dooner.  Maria is a practitioner-in-residence at the Janet R. Spragens Federal Tax Clinic at American University’s Washington College of Law.  She returns to help us understand the 9th Circuit’s recent decision regarding attorney’s fees.  Keith As Keith discussed here, the Ninth Circuit recently issued its opinion on Tung
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