Recent Passport Cases in the Tax Court
In 2015, Congress added §7345 to the Internal Revenue Code (IRC). Under §7345(a), if the Internal Revenue Service (IRS) certifies that a taxpayer has a “seriously delinquent tax debt,” a taxpayer may h... Thomas Gorczynski, 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
IRS Crackdowns and Expatriate Tax Compliance
In the past year, the IRS has released new compliance initiatives that target expatriates (expats), specifically. As part of these crackdowns, enrolled agents (EAs) are likely to see a rise in noncompliance notices, passport revocations, and other penalties. While these puni... David McKeegan, EA