Under the BBA partnership rules, after an IRS audit is completed, the general rule is that an imputed underpayment is imposed on the partnership rather than on the partners. This liability is computed by netting all adjustments and multiplying by highest individual tax rate (39.6%), unless partnership can show rate should be lower. IRC section... Read More

IR-2020-203, September 8, 2020 WASHINGTON — Later this month, the Internal Revenue Service will start mailing letters to roughly nine million Americans who typically don’t file federal income tax returns who may be eligible for, but have not registered to claim, an Economic Impact Payment. The letters will urge recipients to register at IRS.gov by October... Read More

IR-2020-199, September 1, 2020 WASHINGTON- The IRS announces the launch of the Bi-Partisan Budget Act (BBA) Centralized Partnership Audit Regime webpage. The Centralized Partnership Audit Regime replaces the Tax Equity and Fiscal Responsibility Act (TEFRA) and the electing large partnership rules. The centralized partnership audit regime, or BBA, is generally effective for tax years beginning... Read More

IR-2020-66, April 9, 2020 WASHINGTON — To help taxpayers, the Department of Treasury and the Internal Revenue Service announced today that Notice 2020-23 (PDF) extends additional key tax deadlines for individuals and businesses. Last month, the IRS announced that taxpayers generally have until July 15, 2020, to file and pay federal income taxes originally due on... Read More

From the IRS newsroom IR-2020-55, March 12, 2020 WASHINGTON — The Internal Revenue Service today announced the release of final regulations that increase the Offer in Compromise application fee to $205 and provide an additional way for the IRS to waive the Offer in Compromise application fee for low-income taxpayers, based on their adjusted gross... Read More

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... Read More

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... Read More

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),... Read More

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... Read More