Late-Filed Collection Due Process Requests May Now Be Honored
If a taxpayer has an unpaid tax debt, the Internal Revenue Service (IRS) may take certain enforced collection actions provided it gives the taxpayer a right to contest those actions. Under §632... Thomas Gorczynski, EA, USTCP
Say Goodbye to Most Form 5471 Penalties
Alon Farhy used two Belize corporations to attempt to evade United States income tax. While he was not prosecuted for these actions, he also never filed Form 5471, Information Return of U.S. Persons With Respect to Certain Fore... Thomas Gorczynski, EA, USTCP
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
What Is the Big Deal About Boechler?
A tax-related U.S. Supreme Court (SCOTUS) case is always notable, and Boechler is no exception. The key issue in Boechler is whether the 30-day time limit for filing a Tax Court petition–described in Internal Revenue Cod... Phyllis Jo Kubey, EA
Collection Due Process as Viewed by the Tax Court
Internal Revenue Service Collection Process When taxpayers cannot pay their taxes, the Internal Revenue Service (IRS) has voluntary and enforced collection alternatives available. Taxpayers can enter into installment agreements that... Sherrill Trovato, EA, USTCP
What Jurisdiction Does the Tax Court Have Over Passport Actions Under §7435(b)?
Vivian Ruesch, Petitioner v. Commissioner of Internal Revenue, Respondent 154 T.C. 13 | Filed June 25, 2020 Vivian Ruesch (154 T.C. 13 (6/25/20)) provides the first Tax Court guidance on Internal Revenue Code (IRC) §7345, captioned “Revocat... Sherrill Trovato, EA, USTCP