tax Archive
Tax Court Temporarily Stops Issuing Dismissals for Lack of Jurisdiction of Late Deficiency Petitions
May 17, 2022
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This is an update to the post of May 3, 2022, which discussed a May 2, 2022 motion to vacate a dismissal for lack of jurisdiction of a late-filed deficiency case in Hallmark Research
IRS blames old tech in destruction of information returns
May 16, 2022
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TweetShareSharePin0 Shares The IRS said Thursday that it destroyed approximately 30 million unprocessed information returns because its “antiquated technology” forced it to dispose of the paper documents and vowed to process all such information returns that it received in 2021 and 2022. The IRS statement was in response to an audit report by the Treasury
IRS Not Giving Up on Thorny SOL Issues When Taxpayer Fails to Backup Withhold
May 16, 2022
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TweetShareSharePin0 Shares An issue that is often litigated is whether and when a return is deemed filed for purposes of starting the SOL on assessment. In today’s post, I will discuss Quezada v US and the IRS’s decision to publish an Action on Decision disagreeing with the Fifth Circuit. We have not discussed AOD’s though
The 9th Circuit reverses the Tax Court finding that the taxpayer had filed a return when it provided a copy to the IRS during its examination
May 13, 2022
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TweetShareSharePin0 Shares We welcome back guest blogger Janice Feldman. Janice is currently a volunteer attorney at the Harvard Law School Federal Tax Clinic and assisted in drafting the amicus brief filed by the clinic on behalf of the Center for Taxpayer Rights in Seaview Trading, LLC v. Commissioner. Prior to volunteering at the clinic, Janice
Surpluses, Confirmations, And Tax Breaks
May 13, 2022
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TweetShareSharePin0 Shares The US posted a $308 billion budget surplus in April. Source link TweetShareSharePin0 Shares
Court Blesses Offset Before Pandemic When Later Filed Return Would Have Been Treated Differently
May 12, 2022
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TweetShareSharePin0 Shares In Seto v United States the Court of Federal Claims held that it was permissible to apply a taxpayer’s 2019 federal income tax refund to offset defaulted student loans dating back nearly 30 years. In the case, Seto argued that Treasury unlawfully offset the refund because if he had filed his 2019 return
Missed Deadlines and Damages For Wrongful Disclosure
May 11, 2022
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TweetShareSharePin0 Shares When the IRS releases a taxpayer’s confidential tax return information to an unauthorized person that taxpayer has a private right of action against the United States for damages. The case of Castillo v US concerns a taxpayer who sought damages after she claimed, and the government admitted, that Appeals improperly sent a CDP
Inflation, Rocky Markets, Corporate Tax Incidence, and Cheesesteak
May 11, 2022
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TweetShareSharePin0 Shares Biden: Whip inflation now. He didn’t quite say that but at a White House event yesterday, Biden said controlling inflation is now his top priority: “I know families all across America are hurting because of inflation. I want every American to know that I am taking inflation very seriously.” Biden’s said his agenda
What sources do states generate their tax revenue from?
May 11, 2022
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TweetShareSharePin0 Shares It’s been said that the only two certainties in this life are death and taxes. That’s especially true when it comes to state income tax sources, which are a bit of a trickier situation than most. To be clear, no individual is typically very enthused about paying taxes. Yet at the same time,
How Democrats Who Want To Tax The Very Wealthy Are Taking A Page From Thomas Paine
May 10, 2022
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TweetShareSharePin0 Shares Did President Biden and other Democrats read 18th century revolutionary Tom Paine before they proposed their taxes on extreme wealth? Hard to know, but the striking similarities between their efforts to tax the mega-rich and Paine’s suggest they might have. It turns out that Paine, who was too revolutionary for most of his
