Is the Deadline to File a Tax Court Petition Jurisdictional?
Whether the deadlines to file a United States Tax Court petition are jurisdictional has been a developing issue over the last two years and has been discussed in previous issues of the EA Journal (see the Fall 2023 and Spring 2024 Tax Cou... Thomas Gorczynski, EA, USTCP
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
Lessons from a Rogue Revenue Officer
I do not have scientific data to back this up, but my 30 years’ experience has led me to believe that something along the lines of 98 percent of the folks at the Internal Revenue Service (IRS) are ha... John A. Mitchell, EA
What Happens When a Tax Court Petition Is a Few Minutes Late?
The United States Tax Court is a court of limited jurisdiction; it cannot consider every tax dispute in the United States. Historically, for the Tax Court to have jurisdiction over a specific matter, the Internal Revenue Code (IRC) must allow the Tax Court to review the Inte... 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
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
An Introduction to the Supervisorial Approval of Penalties Under Internal Revenue Code Section 6751(b)
Internal Revenue Code (the IRC or the Code) §6751(b)’s supervisory approval requirement has been a hotly litigated issue over the past few years. This article will introduce you to §6751(b) and help explain how supervisory approval is obt... Frank Agostino and Phillip J. Colasanto