The Tax Equity and Fiscal Responsibility Act of 1982 (“TEFRA”) procedures were intended to make it easier for the IRS to audit partnership tax returns. TEFRA failed to deliver. The rules are nuanced and hard to apply. The new partnership …..
The IRS often willing to abate or remove tax penalties. To do so, taxpayers usually have to show that they acted with reasonable cause and in good faith. Relying on a competent tax professional can be one way taxpayers can …..
In Ford Motor Co. v. United States, No. 14-458T (Ct. Cl. 2017), the court addressed whether a wholly owned corporation and its parent were the “same corporation” when computing the amount of interest the taxpayer owed to the IRS. This …..
If the IRS owes the taxpayer a refund, the general rule is that the taxpayer has to file a refund claim with the IRS, wait for the IRS to disallow the claim, and then, within two years of the date …..
Do taxpayers have to use the official forms published by the IRS? There are laws and administrative guidance that allow taxpayers to provide the information requested to the IRS without using the actual IRS form in some circumstances. In May …..
The IRS can use the duty of consistency doctrine to disallow tax deductions, credits, etc. in the current year when the deduction, credit, etc. in the current year is based on facts that differ from facts reported to the IRS …..
In Ervin v. United States, No. 4:13-CV-00127-JHM (W.D. Ky. 2017), the court considered whether the government can withhold or set off a penalty refund owing to a taxpayer if the taxpayer has already recovered the amount in excess of the …..