tax Advice Archive
The Sixth Circuit Holds IRS Notice Issued in Violation of the APA; District Court in CIC Services Finds Case is Binding Precedent
March 22, 2022
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TweetShareSharePin0 Shares Preface: This discussion of Mann Construction v US discusses the possible implications of the opinion on the remanded case of CIC Services v IRS, mentioned in the conclusion of this post. Last night in CIC Services v IRS, a federal district court in Tennessee held that the opinion in Mann Construction “is binding
General Discharge Denial in Chapter 7 Based on Taxes
March 21, 2022
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TweetShareSharePin0 Shares I have written before on many occasions about taxpayers who sought a discharge of their tax debts through chapter 7 bankruptcy. For individuals filing chapter 7, the basic discharge provisions exist in BC 727, but I have always previously discussed the exceptions to discharge in BC 523(a)(1) and (7). In the case of
Making the IRS Answer to Taxpayer Inquiries…By Making the IRS Reasonably Inquire (Part Two)
March 18, 2022
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TweetShareSharePin0 Shares Lately I’ve been obsessing over how to remedy “bad answers” from the IRS). In my last post, I detailed how IRS counsel’s failure to “reasonably inquire” under Rule 33 before filing a “bad answer” may make them more susceptible to awards of litigation costs under IRC § 7430. Of course, litigation costs come
IRS will clear backlog by year’s end
March 17, 2022
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TweetShareSharePin0 Shares IRS Commissioner Charles Rettig told House members in a hearing Thursday that the Service will process its backlog of unprocessed work — some of it dating back to 2020 — by the end of 2022. Rettig appeared before the House Ways and Means Committee’s Subcommittee on Oversight to report on the current filing
IRS beset by processing backlogs, hiring lags in 2021
March 17, 2022
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TweetShareSharePin0 Shares Millions of tax returns from the 2020 filing season still awaited processing by late that year, hampering the IRS’s ability to provide timely service in 2021 and likely contributing to ongoing backlogs in the current filing season, the Treasury Inspector General for Tax Administration (TIGTA) said in an audit report. The report, Results
Making the IRS Answer to Taxpayer Inquiries…By Making the IRS Reasonably Inquire
March 17, 2022
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TweetShareSharePin0 Shares In my last post, I piqued your interest by mentioning ways to remedy “bad answers” from the IRS – the sorts of answers where IRS Counsel blandly denies every factual allegation for lack of sufficient information. Then, I proceeded to discuss instances where the IRS either doesn’t answer at all or doesn’t answer
Auto depreciation limits leap with inflation
March 16, 2022
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TweetShareSharePin0 Shares The IRS issued sharply higher new depreciation limitations Wednesday for passenger automobiles, reflecting inflation of vehicle prices in the past year. These limits are updated annually for inflation according to the automobile component of the chained consumer price index for urban consumers. Rev. Proc. 2022-17 contains the Sec. 280F(a) inflation-adjusted dollar limitations on
Making the IRS Answer to Taxpayers…By Making the IRS Answer
March 16, 2022
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TweetShareSharePin0 Shares Teachers will sometimes say there is no such thing as a bad (or “stupid”) question. I’d say the jury is out on that one. Everyone, however, can agree that there is such a thing as a bad answer (see Keith’s recent post here). My next few posts will detail a particular kind of
Loretta Collins Argrett Fellowship
March 15, 2022
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The ABA Tax Section has created a new fellowship that brings recipients to its meetings and provides other significant benefits described below. Check it out if you are interested or know someone who might be
How Did We Get Here? Correspondence Exams and the Erosion of Fundamental Taxpayer Rights – Part 2
March 15, 2022
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TweetShareSharePin0 Shares In my last post, I reviewed compelling IRS data, including from the National Taxpayer Advocate’s 2021 Annual Report to Congress, that show the IRS Automated Correspondence Exam (ACE) system disproportionately harms low income taxpayers and is desperately in need of a fix. The IRS maintains the batch processing approach to correspondence (corr) examinations
