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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 a law that provides for authority for the IRS to assess the Trust Fund Recovery Penalty (TFRP). These taxes are called trust fund taxes because the business holds the employee’s money in trust...
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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 rule is that judicial filing deadlines in tax are jurisdictional and are not subject to equitable tolling under recent Supreme Court case law. For example, pertaining CDP Tax Court jurisdiction, Internal Revenue Code...
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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 and Procedure, including new Title XXIV.A (Partnership Actions Under BBA Section 1101), and certain conforming and miscellaneous amendments. The Court has also adopted revisions to Form 1 (Petition), Form 7 (Entry of Appearance),...
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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 the IRS Collection office that initiated the collection action. Appeals ensures and protects its independence by adhering to a strict policy of prohibiting certain ex parte communications with the IRS Collection office or...
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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) § 7602 provides the Internal Revenue Service with summons authority. IRC § 7601 authorizes the IRS to inquire about any person or taxpayer who may be liable to pay any internal revenue tax. Moreover,...
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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 BBA centralized audit regime? Also, how will the new BBA audit regime impact their partnership? Moreover, taxpayer’s ask whether a partner can file an inconsistent tax return. The Bipartisan Budget Act of 2015...
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