How to Elect Out of the IRS BBA Centralized Partnership Audit Regime
Taxpayers often ask their taxpayer how can a partnership elect out of the centralized partnership audit regime. This tax blog article provides... Read More
Appealing the Trust Fund Recovery Penalty
To encourage payment of withheld income and employment taxes, including social security taxes, railroad retirement taxes, or collected excise taxes, Congress passed... Read More
D.C. Circuit Holds Tax Court Whistleblower Award Filing Deadline Not Jurisdictional and Subject to Equitable tolling
Many taxpayers ask their tax attorney whether various deadlines by which to take actions are fixed or can be extended. The general... Read More
United States Tax Court has adopted final amendments to its Rules of Practice and Procedure, including new Title XXIV (Partnership Actions Under BBA Section 1101)
Chief Judge Maurice B. Foley announced today that the United States Tax Court has adopted final amendments to its Rules of Practice... Read More
Can I submit an Offer in Compromise through a CDP Hearing?
You may appeal many IRS collection actions to the IRS Independent Office of Appeals (Appeals). Appeals is separate from and independent of... Read More
IRS Safe Harbor for the Qualified Business Income Deduction for Real Estate
The Internal Revenue Service has issued Revenue Procedure 2019-38 (PDF) that outlines a safe harbor allowing particular interests in rental real estate to... Read More
How Does the CDTFA Audit Bundled Cell Phone Sales?
People often ask their tax lawyer how to respond to the CDTFA when they receive an audit letter. A CDTFA audit can... Read More
What Should I do If I Receive an IRS Summons?
Taxpayers frequently ask their tax attorney what they need to do if they receive an IRS summons. Internal Revenue Code (IRC) ยง... Read More
What is the New Centralized Partnership Audit Regime?
The Internal Revenue Service has a new audit regime to administer. Taxpayers frequently have asked their tax attorney: what is the new... Read More
IRS CDP HEARINGS AND TAX COURT LITIGATION
Taxpayers often ask their tax attorney what they can do to dispute a tax liability or collection action when they receive an... Read More