TAXES Archive
Category 9 Cases the Taxpayer Advocate Service Will Accept
June 2, 2021
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TweetShareSharePin0 Shares TAS wants to assist taxpayers in situations in which it can provide meaningful assistance but does not want to waste time where it cannot help. A good example of a place where it cannot help has occurred because of the pandemic. Many taxpayers want to know what has happened to their refund or

Inheritance, Estate, and Gift Taxes in OECD Countries
June 1, 2021
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TweetShareSharePin0 Shares In a recent report that reviews inheritance taxation in OECD countries, the Organisation of Economic Co-operation and Development (OECD) concludes that inheritance taxes could play a key role in reducing inequality while increasing countries’ tax revenues. When analyzing the wealth distribution in 27 OECD countries, the report finds that in 2015, on average,
TIGTA Releases Report on Improper Payment Rate For Refundable Credits
June 1, 2021
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TweetShareSharePin0 Shares Last month TIGTA released its annual review of the IRS’s improper payment reporting requirements under the Payment Integrity Information Act (PIIA). The focus in this TIGTA report is the IRS’s administration of refundable credits. In the pre-COVID time frame (FY 20), OMB determined that the Earned Income Tax Credit (EITC), Additional Child Tax Credit (ACTC), and American Opportunity
President’s budget contains many tax proposals
May 28, 2021
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TweetShareSharePin0 Shares President Joe Biden’s administration unveiled its proposed budget for fiscal year 2022 on Friday. Treasury says the $6 trillion proposed budget focuses on infrastructure, clean energy, and research and development, and among its many provisions are a host of proposed tax changes affecting individuals and corporations. One set of tax and revenue proposals,
Follow Up Information on Tax Court Service of Petitions
May 28, 2021
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TweetShareSharePin0 Shares Yesterday, we published some data from Carl Smith showing that the service of a new Tax Court petition on the office of Chief Counsel was taking about two months. Following that observation, Carl did some additional digging and found the service time to vary considerably. Below is a chart of his most recent
Draft employer’s payroll tax return incorporates ARPA changes
May 27, 2021
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TweetShareSharePin0 Shares The IRS on Tuesday released a draft revised 2021 version of Form 941, Employer’s Quarterly Federal Tax Return, reflecting further new and updated payroll tax credits. The current official version was released less than three months earlier on March 9, and the impending further changes reflect Congress’s multiple provisions of temporary payroll tax
Things That Make You Say Hmmm
May 27, 2021
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TweetShareSharePin0 Shares We welcome back guest blogger and commenter in chief, Bob Kamman. As usual, Bob has found things that the rest of us overlook. In addition to the interesting twists on the way things work that Bob discusses below, I received a message from Carl Smith who, though retired, still takes some interest in
Substantial Understatement Penalties and Supervisory Approval: Big Changes Coming?
May 26, 2021
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TweetShareSharePin0 Shares Procedurally Taxing has been at the forefront covering the evolution of the “supervisory approval” requirements of IRC § 6751 (see posts here, here and here). The most recent post from Patrick Murray, a University of Minnesota Law student, argued that in its present, post-Walquist form, IRC § 6751 is of little help to
Revisiting Supervisory Approval For Accuracy Penalties
May 25, 2021
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TweetShareSharePin0 Shares Today’s post comes from University of Minnesota Law student, Patrick Riley Murray. Mr. Murray is not actually one of my students in my Federal Tax Procedure or the Federal Tax Clinic courses. However, Mr. Murray was referred to me by a student and previous Procedurally Taxing contributor Casey Epstein (see post here), as

Sorting out tax exempts’ UBTI painlessly
May 24, 2021
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TweetShareSharePin0 Shares Two digits are mostly better than six In comments to the IRS on the proposed regulations, the AICPA called for much broader two-digit codes to eliminate the complexity posed by using six, and opposed mandating the codes’ use. The new silo requirement originally “created a lot of confusion and left people guessing,” Heller