tax Archive
Circuit Split on Notice Rules For Summonses to Aid Collection
January 20, 2022
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TweetShareSharePin0 Shares The recent Sixth Circuit case Polselli v United States results in a split in the circuits on a fundamental issue in IRS summons practice: does the IRS have to give notice when it issues a summons in the aid of collecting an assessed tax? Polselli involves IRS summonses issued to third party recordkeepers

Summary of the Latest Federal Income Tax Data, 2022 Update
January 20, 2022
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TweetShareSharePin0 Shares The Internal Revenue Service (IRS) has released data on individual income taxes for tax year 2019, showing the number of taxpayers, adjusted gross income, income tax paid, and income tax shares by income percentiles.[1] The new data outlines the tax system under the second year of the Tax Cuts and Jobs Act (TCJA),
IRS issues procedures for employee status determinations
January 19, 2022
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TweetShareSharePin0 Shares The IRS issued procedural guidance Wednesday regarding determinations by the Service that a worker is properly classified as an employee of an employer rather than an independent contractor. The distinction carries significant employment law and tax ramifications. The latter include that a person for whom services are performed must withhold from employees’ wages
Refund Claims and Section 7508A
January 19, 2022
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TweetShareSharePin0 Shares Bob Probasco, a regular guest poster, has joined Procedurally Taxing as a contributor. In today’s post, Bob unravels the intersection of the suspension rules of Section 7508A and the refund lookback limits in Section 6511. Les In normal years, the President may make multiple regional disaster declarations; in 2020, we had a nationwide disaster declaration related to

State Corporate Income Tax Rates and Brackets for 2022
January 18, 2022
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TweetShareSharePin0 Shares Key Findings Forty-four states levy a corporate income tax. Rates range from 2.5 percent in North Carolina to 11.5 percent in New Jersey. Six states—Alaska, Illinois, Iowa, Minnesota, New Jersey, and Pennsylvania—levy top marginal corporate income tax rates of 9 percent or higher. Eleven states—Arizona, Colorado, Indiana, Kentucky, Mississippi, Missouri, North Carolina, North
AICPA joins coalition seeking relief from IRS service challenges
January 14, 2022
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TweetShareSharePin0 Shares As part of a diverse coalition of organizations representing tax professionals and other stakeholders — and in light of the continuing COVID-19 pandemic — the AICPA on Friday called on the IRS and Treasury to implement taxpayer relief from penalties and certain other compliance actions. The AICPA was among parties signing a letter
FAQs address calculation and reconciliation of recovery rebate credit
January 14, 2022
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TweetShareSharePin0 Shares The IRS on Thursday issued a fact sheet (FS-2022-04) of frequently asked questions (FAQs) intended to help taxpayers and their return preparers calculate the recovery rebate credit for 2021 tax returns. The recovery rebate credit for the 2021 tax year, as for 2020, must be netted against any economic impact payment (EIP) a
NTA Report Released: Essential Reading
January 14, 2022
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TweetShareSharePin0 Shares Earlier this week the NTA released the 2021 Annual Report to Congress (link to full report). The report also includes as a separate volume the 2022 Purple Book, which lists 68 legislative recommendations that focus on ways to strengthen taxpayer rights and improve tax administration. Both the Annual Report and the Purple Book

Only in Florida: DeSantis’s Proposal to Suspend the Gas Tax with ARP Dollars is Doubly Wrong
January 14, 2022
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TweetShareSharePin0 Shares Florida Governor Ron DeSantis wants to use $1 billion in American Rescue Plan (ARP) funds to suspend Florida’s gas tax for five months. Suspending the gas tax is a bad idea, full stop. Funding a gas tax suspension with federal funds intended to address a public health crisis, in the middle of the
Tax Judgments and Quiet Titles
January 14, 2022
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TweetShareSharePin0 Shares I have written before about the effect of the IRS obtaining a judgment with respect to a tax assessment. In Boykin v. United States, No. 5:21-cv-00103 (W.D.N.C. 2022), the fact that the IRS had a judgment carries the day in a contest with a taxpayer involving a quiet title action. The case provides