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TAX PREPARATION Archive

IRS Wins Lien Priority Fight with Bank

TweetShareSharePin0 Shares In Citizens Bank, N.A. v. Nash, No. 2:20-cv-00351 (E.D. Pa. 2021) a lien priority fight occurred between the IRS and the bank holding the taxpayer’s mortgage.  In many ways the bank’s problem reminded me of problems that routinely plague the IRS in lien priority fights.  The bank erroneously recorded a release and that

Incarcerated Individual Subject to Delinquency Penalties Even Though Attorney Embezzled Funds and Failed To File His Tax Returns

TweetShareSharePin0 Shares We have often discussed the reach of the 1985 Supreme Court case United States v. Boyle. Section 6651(a)(1) and (2) impose delinquency penalties for failing to file a tax return or pay a tax unless the taxpayer can establish that the failure was due to reasonable cause and not willful neglect.  Boyle essentially stands for

IRS Taking Payments Beyond Ten Years of Assessment Still Timely

TweetShareSharePin0 Shares Dean v US involves a motion to dismiss a taxpayer’s suit alleging that the IRS recklessly disregarded the law by continuing to levy on a taxpayer’s Social Security payments beyond the ten year SOL on collections.  The magistrate concluded that the IRS’s actions were not improper and recommended that the case be dismissed. The

How Tax Regulations Are Made

TweetShareSharePin0 Shares Today’s post is by frequent guest poster Monte Jackel, Of Counsel at Leo Berwick. In today’s post, Monte discusses his reactions to an article written by Shu-Yi Oei of Boston College Law School and Leigh Osofsky of the University of North Carolina at Chapel Hill. A few years ago they wrote an insightful article on the process that led to

More Clarity on CSED Problem

TweetShareSharePin0 Shares In January of this year I wrote about a problem with the Collection Statute of Limitations (CSED) that my clinic encountered.  In our quest to resolve the CSED problem, we involved the Local Taxpayer Advocate office.  It confirmed that the CSED had run, despite the fact that the taxpayer’s account was still open,

Issues with Automated Guidance

TweetShareSharePin0 Shares Following my post from last month, I write again about academic research related to the IRS’s technology plans. This time with an additional focus on some of the potential pitfalls and concerns. The government provides resources, information and assistance to help the public understand and apply the law. Technology has allowed the government
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