When Is a Return Considered Filed?
Representation

When Is a Return Considered Filed?

In Seaview Trading, LLC v. Commissioner,i a three-judge panel of the Ninth Circuit Court heard an appeal from the Tax Court, which tasked the court with deciding when a return ... Josh Youngblood, EA

If the IRS Timely Responded, Your Offer Is Not Deemed Accepted
Tax Court

If the IRS Timely Responded, Your Offer Is Not Deemed Accepted

Brown v. Commissioner, 158 T.C. No. 9 (2022) Brown has shined light onto a provision in the Internal Revenue Code (IRC) that asserts that an offer is deemed accepted 24 months after submission if not explicitly rejected.Ruben D. Valdes, EA, USTCP