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Relying on an Attorney for a Tax Filing Deadline is Reasonable Cause

In Estate of Hake v. United States, No. 1:15-CV-1382 (M.D. Pa 2017), the court considered whether relying on an attorney for when a tax return had to be filed, rather than relying on the attorney to file the tax return, was reasonable cause. The case should make it easier to get failure-to-file penalties removed for taxpayers in Delaware, New Jersey, and Pennsylvania and will no doubt be cited by taxpayers in other states as well.

The Facts

In Hake, the taxpayer hired an attorney. The attorney told the taxpayer that they had obtained an extension of time to file their tax return. The taxpayer then filed their return within the time period specified by the attorney. The attorney was mistaken as to the extended filing deadline, however. The law is clear that the extension was only to pay, not to file. The IRS assessed a failure to file penalty. The attorney admitted his error. The court considered whether taxpayer’s reliance on the attorney’s error was reasonable cause.

Reasonable Cause

There is no bright line rule that defines the term “reasonable cause.” There is no succinct summary that can even defines the contours of what facts may qualify for reasonable cause. Instead, there is only a body of case law that largely says what is not reasonable cause. So one can only rely on court cases that say what is not reasonable cause to establish reasonable cause given different facts.

Most attempts to define reasonable cause are framed in terms of the Supreme Court’s United States v. Boyle, 469 U.S. 241, (1985) decision. Boyle stands for the proposition that a taxpayer cannot establish reasonable cause by simply delegate their filing obligation to an attorney who fails to file on time. As noted in Hake, the Boyle case does not go any further than this.

Categories of Late Tax Return Filing Cases

The court in Hake identified the following three types of late tax return filing cases:

In the first category consists of cases that involve taxpayers who delegate the task of filing a return to an agent, only to have the agent file the return late or not at all. Id. (citing Boyle, 469 U.S. at 249-50). In Boyle, the Supreme Court held that in such cases, reliance upon one’s attorney to file a timely tax return was not reasonable cause to excuse the late filing. Id. The second category of late-filed cases identified in Boyle, as that decision is construed by the court of appeals in Thouron, is where a taxpayer, in reliance on the advice of an accountant or attorney, files a return after the actual due date, but within the time that the taxpayer’s lawyer or accountant advised the taxpayer was available. Id. Finally, in the third category are those cases where “an accountant or attorney advises a taxpayer on a matter of tax law[.]” Id. (quoting Boyle, 469 U.S. at 251) (emphasis in Boyle).

With respect to the second and third type of cases, the court noted that:

…the holding of Boyle does not reach the very circumstances of this case, where the executors did not delegate their filing duty to their lawyer, but where they did rely upon their lawyer to advise them when their taxes needed to be paid and their return filed….


in Boyle the Supreme Court expressly declined to address the question of whether a taxpayer demonstrates “reasonable cause” when, in reliance upon the advice of counsel, the taxpayer files a return “after the actual due date but within the time the adviser erroneously told him was available.”

The court also noted the split in authroity for this issue:

In reaching this result, we recognize that some other courts have interpreted Boyle in the manner urged by the United States, and on facts that are substantially similar to those presented in this case. See, e.g., Knappe v. United States, 713 F.3d 1164 (9th Cir. 2013); West v. Koskinen, 141 F.Supp.3d 498 (E.D. Va. 2015).

The Ninth Circuit includes California, Arizona, Nevada, Oregon, Washington, Montana, and Idaho.

Discount Loyalty Programs are Not Trading Stamp Companies

Accrual method taxpayers generally must recognize advance payments in taxable income in the year of receipt, because receipt satisfies the all events test. The trading stamp rules are an exception to this all-events test. These rules apply to businesses that have customer loyalty programs.

The rules can result in significant tax deferral as they allow the taxpayer to receive income now and defer recognition of a portion of the income to a future date when the customer takes advantage of the loyalty program. For example, if the taxpayer sold merchandise for $100 and issued 10 points to the customer as part of its loyalty program, the trading stamp rules would say that a portion of the $100 is for the 10 points and, based on mathematical calculations, it is not likely that all 10 of the points will be redeemed in the current year. So the trading stamp company rules allow the taxpayer to defer part of the $100 of income they received to account for this reality.

There is little guidance that addresses trading stamp companies, which is surprising given the large amounts that are at stake. This brings us to the topic of this post. The IRS recently issued Attorney Memo 2017-002 to clarify its position that hybrid coupons are discount coupons that do not qualify for this tax deferral.

The Trading Stamp Company Rules

The trading stamp company rules are found in Sec. 453 of the Code. They generally say that a trading stamp company can subtract from income both (1) the cost of merchandise, cash, and other property used for redemptions in the taxable year and (2) the net addition to the provision for future redemptions during the taxable year. It is this second element that can result in the tax deferral and savings, as it allows the accrual to be subtracted from income in the current tax year and deferred to a later year. This can be particularly beneficial if the coupons, points, etc. for the customer loyalty program are not redeemed for several years.

This begs the question as to what type of loyalty programs qualify. There has been little guidance on this issue. The IRS’s recent AM 2017-002 address this topic by considering the difference between premium, discount, and so-called hybrid coupons offered by loyalty programs.

Premium Coupons

Premium coupons are specifically listed as qualifying in Sec. 453. They are not defined in this code section, however. In AM 2017-002, the IRS provides a definition by looking to the explanation provided by the Joint Committee on Taxation:

A premium coupon … generally is issued in connection with the sale of some item and entitles the holder to tender it (or, more usually, a large number of such coupons) in exchange for a product, often selected from a catalog, of the consumer’s choosing. These coupons are used to promote the sale of the product with which the coupon is issued by allowing the consumer to collect coupons in order to acquire a different product.

The coupon is used to acquire a different product than the one being purchased when the coupon is issued. It is used to get a free product.

Discount Coupons

According to the IRS’s AM 2017-002, a premium coupon is different than a discount coupon. The IRS’s memo defines a discount coupon by looking at former Sec. 466, which has been repealed:

A discount coupon is a sales promotion device used to encourage the purchase of a specific product by allowing a purchaser of that product to receive a discount on its purchase price. … A discount coupon normally entitles its holders to receive nothing more than a reduction in the sales price of one of the issuer’s products. The discount may be stated in terms of a cash amount, a percentage or fraction of the purchase price, a ‘two for the price f one’ deal, or any other similar provision. A discount coupon need not been printed on paper in the form usually associated with coupons; it may be a token or other object so long as it functions as a coupon.

The IRS notes that discount coupons apply to a specific product. The focus is on a discounted product.

Hybrid Coupons

The IRS’s AM 2017-002 goes on to define hybrid coupons as being a mix of premium and discount coupons:

[H]ybrid coupons can be viewed as discount coupons allowing a member to acquire enough coupons to receive a discount off the purchase of a product. After a member has acquired a sufficient number of hybrid coupons to receive a discount on the purchase of an item, the member may also continue accumulating coupons until the purchase price is reduced to zero. However, the fact that a discount coupon may be accumulated in sufficinet quantities to result in a free product does not alter the nature of the coupon as a discount coupon. Thus, hybrid coupons are more properly characterized as discount coupons and are not premium coupons under section 1.451-4 because the nature of hybrid coupons, like discount coupons, is that of a price reduction.

The IRS memo concludes that hybrid coupons are more akin to discount coupons and, as such, they do not qualify for the trading stamp company rules.

Planning for Tax Refunds in Bankruptcy

Given that it is tax season, the In re Porter, No. 16-11831-BFK (E.D. Vir. 2017) case serves as a timely reminder that taxpayers who have unpaid tax debts and who are expecting sizeable tax refunds may benefit from timing the filing of their bankruptcy cases.

Facts & Procedural History

The facts and procedural history are as follows:

  • The taxpayer filed her 2014 tax return on April 4, 2016.
  • The tax return reflected a $4,169.00 tax refund.
  • The IRS set off the refund against the taxpayer’s unpaid taxes for 2012 on May 2, 2016.
  • The taxpayer filed Chapter 7 bankruptcy on May 25, 2016.
  • The taxpayer’s bankruptcy petition listed the tax refund as being exempt.
  • The taxpayer filed a motion to recover the tax refund claiming that the setoff was an illegal preference.

Right to Tax Refund as of the End of the Year

The IRS argued that the taxpayer had no right to the refund claim until the IRS set off the refund to satisfy the taxpayer’s unpaid tax debt. The court did not agree. It noted that the taxpayer had a right to the tax refund as of midnight on December 31, 2014, the last day of the taxable year, and the refund belonged to the taxpayer until the time the government issued notice and actually set off the refund on May 2, 2016.

IRS Setoff Allowed if No Improved Position

The IRS also argued that it did not improve its position by setting off the tax refund on May 2, 2016. The bankruptcy rules generally void a setoff that results in the creditor obtaining more than it would as part of the bankruptcy case if the setoff occurred within 90 days of the bankruptcy petition being filed. The court agreed with the IRS. Since the taxpayer filed her bankruptcy petition on May 25, 2016, 90 days prior to this date was February 26, 2016. As of February 26, 2016, the IRS owed the taxpayer and the taxpayer owed the IRS. So the requirements for the setoff had occurred prior to the 90 day pre-petition time period–even though the actual setoff occurred during the 90 day pre-petition time period.

The taxpayer argued that the IRS improved its position when the taxpayer filed its tax return on April 4, 2016, which was within the 90 days prior to filing the bankruptcy petition. The court did not agree. It noted that the tax return filling had not bearing on this issue, as the taxpayer had a right to the refund prior to this time, namely, as of December 31, 2014.


Issues involving tax refunds can be one of the most difficult aspects of bankruptcy and tax law. These rules rules require careful planning. Not only are they result in the loss of the tax refunds, they can also result in the bankruptcy case being converted or even dismised.

How to Challenge an Invalid IRS Notice of Deficiency

The IRS is required to send taxpayers a notice of deficiency before it can assess additional tax. The notice itself has to put the taxpayer on notice that the IRS made a determination that there was a tax deficiency (i.e., an amount owed), the tax year, and the amount. A notice that does not include one or more of these items may be invalid and, if enough time has passed, can prevent the IRS from lawfully assessing the tax. The U.S. Tax Court set out a two-prong test in Dee v. Commissioner, 148 T.C. No. 1 (2017), that may make it more difficult for taxpayers to challenge invalid notices.

The Facts and Procedural History

The facts and procedural history are as follows:

  • The taxpayer filed his 2014 tax return.
  • The IRS disallowed the premium tax credit reported on the return in 2015 by mailing a notice of deficiency to the taxpayer.
  • The notice of deficiency reflected $0.00 as the deficiency amount.
  • The notice also included tax calculations and indicated that “[a] decrease to refundable credit results in a tax increase.”
  • The taxpayer filed a petition with the U.S. Tax Court to challenge the disallowance of the premium tax credit.

The court asked the IRS to explain how the court had jurisdiction over the case if there was a tax deficiency in the amount of $0.00. The IRS responded that this was a clerical error and that it did not invalidate the notice of deficiency.

The Majority Opinion

The court said this two-prong test is to be used to determine whether a notice of deficiency is valid:

We have often addressed questions regarding the validity of notices of deficiency. We have at times characterized our review of the sufficiency of a notice as an objective test. But our caselaw shows that an objective review is used to establish prima facie validity of a notice of deficiency. When that objective review has led us to conclude that a notice was ambiguous, we have looked beyond the notice to determine whether the Commissioner made a determination and whether the taxpayer knew or should have known that the Commissioner determined a deficiency.

The court viewed the objective test as a “should have known” test and the subjective test as a “knew” test.

The court explained the objective test as follows:

we look to see whether the notice objectively put a reasonable taxpayer on notice that the Commissioner determined a deficiency in tax for a particular year and amount. If the notice, viewed objectively, sets forth this information, then it is a valid notice. … Accordingly, if the notice is sufficient to inform a reasonable taxpayer that the Commissioner has determined a deficiency, our inquiry ends there; the notice is valid.

The court explained the subjective test in light of a prior court case where the taxpayer asserted that he was not mislead by the error in the notice of deficiency. The taxpayer in this prior court case made this admission to allow the court to have jurisdiction. The court also cited another prior court case in which the court concluded that the taxpayer was not misled by the error given the taxpayer had filed a petition with the court contesting the deficiency.

In this case, the court determined that the taxpayer was not misled by the error given the taxpayer had filed a petition with the tax court contesting the deficiency. As such the court concluded that the notice of deficiency was valid and it had jurisdiction over the case.

The Concurring Opinions

One justice issued a concurring opinion to agree with the court’s conclusion, but not its two-prong test for reaching the conclusion:

I disagree that our caselaw supports a test that looks, in part, to whether the taxpayer knew or should have known that the Commissioner determined a deficiency or was misled. The references to a taxpayer’s knowledge or intent and/or to whether a taxpayer was misled in the cases on which the opinion of the Court relies are dicta reinforcing the Court’s conclusion in each case that the Commissioner made a determination in the notice of deficiency that passes jurisdictional muster. We should not elevate those references into a test that has no place in resolving the real jurisdictional issue—whether the Commissioner in the notice of deficiency made a determination with respect to the taxpayer that confers jurisdiction on this Court.

A second justice also issued a concurring option to agree with the court’s conclusion, but not its two-prong test for reaching the conclusion:

The opinion of the Court delineates a two-prong approach (with both objective and subjective elements) to determining our deficiency jurisdiction that is, at best, unnecessary, and is, at worst, improper.

The Dissenting Opinion

A third justice issued a dissent to disagree with the court’s conclusion:

The existence of a deficiency is a notice’s most fundamental requirement. The Commissioner is not required to give the correct deficiency amount, but he is required to determine an amount, and $0 is not a deficiency. The opinion of the Court cites a myriad of cases referencing notices dating back to 1919, see op. Ct. pp. 6-13, yet none of those cases hold valid a notice which informs the taxpayer that he does not have a deficiency.

The Problem with the Result

In a footnote in the dissenting opinion, the justice explained the problem with the court’s two-prong test:

While the notice in this case related to a refundable tax credit, the precedent here will extend to notices issued to increase tax liabilities. Some taxpayers receiving those notices will petition the Court. Their ticket to the Tax Court will also be a ticket to the gallows. Other taxpayers will not file petitions and may ultimately seek relief (i.e., pursuant to sec. 6320 or 6330) when the IRS attempts to collect. If we invalidate $0 deficiency notices, taxpayers would typically prevail in collection proceedings. Instead, our determination of whether the taxpayers were misled will now determine their fate.

The second justice who issued a concurring opinion (as described above), explained it this way:

Even in cases in which the Commissioner sends an inadequate notice of deficiency, the taxpayer does not petition us for redetermination, and tax is subsequently assessed, the taxpayer is not completely out of luck. The taxpayer has the option to pay the assessed tax and pursue a refund claim, after which he or she is entitled to file a suit for refund in a U.S. District Court or the U.S. Court of Federal Claims. Or, if the taxpayer does not become aware of the assessment until receiving a collection notice, the taxpayer can seek relief in a collections due process hearing, after which he or she is entitled to petition this Court for review. Although our caselaw probably would not allow us to find that a taxpayer who receives an inadequate notice of deficiency was not issued a notice of deficiency and thus is entitled to challenge his or her underlying liability under section 6330(c)(2)(B) (as Judge Foley correctly notes in his dissent, see Foley op. note 2, but which is true regardless of the outcome of this case), we could instead find that the Commissioner, in issuing an inadequate notice, failed to fulfill the necessary administrative procedures, including those in the Internal Revenue Manual, under section 6330(c)(1).

What this means is that by filing a petition in tax court, the taxpayer may lose the ability to contest the notice of deficiency in tax court. Even if the case was brought as part of a collection due process hearing, all the taxpayer would get was the case remanded to appeals for further consideration by a settlement officer. To have their day in court, the taxpayer may have to file a refund claim, pay the tax first, sue for a refund and contend with the higher burden imposed on taxpayers in refund litigation.

Bankruptcy Court Says Withholding on Wages Converts the Wages to a Tax

The U.S. Bankruptcy Court recently considered whether amounts withheld from wages in excess of the amount of the income tax liability owed is a refund of tax or a refund of wages. The case is In re Crutch, No. 15-44523-cec. (E.D.N.Y. 2017). The case is a reminder to those taxpayers who are considering bankruptcy that they may need to take steps to ensure that they do not receive tax refunds during their bankruptcy case.

The facts and procedural history are as follows:

  • The dispute relates to a Chapter 7 bankruptcy.
  • The taxpayer’s only income during 2015 was from Social Security and their pension.
  • New York law exempts Social Security and pension income from the bankruptcy.
  • The taxpayers wanted to exempt their 2015 state and IRS tax refunds from the bankruptcy.
  • The bankruptcy trustee asked the court to order the taxpayers to turn over the tax refunds.

The taxpayers argued that the “tax refunds” were not tax refunds; they were a return of Social Security and pension income. If the taxpayers were correct, the income would retain its exempt status under New York and bankruptcy law. This would allow them to keep the tax refunds. If the bankruptcy trustee was right, the “tax refunds” would belong to and have to be turned over to the bankruptcy trustee.

The bankruptcy court considered New York law and a prior court case from the Tenth Circuit Court of Appeals. In considering these laws, the bankruptcy court concluded that the status as wages is lost once the wages were withheld as a tax. The key is withholding.

The case does not address whether the withholding was made in error or in an amount that was excessive.

The case does also not address tax refunds that stem from estimated payments made to the IRS for exempt income that is received. These payments do not have taxes withheld from them. It is up to the taxpayer to pay estimated payments to the IRS. One is left wondering whether the act of remitting the payment to the IRS in an amount in excess of the amount of income tax owed would convert the overpayment to a tax refund in bankruptcy.

Regardless, the message for taxpayers who are considering whether to file bankruptcy is that they need take steps to ensure that they do not generate a “tax refund” during the course of their bankruptcy case. This may mean adjusting withholding amounts (and possibly estimated payments) or looking for ways to defer tax benefits to later years. This may include electing to capitalize and depreciate or amortize property rather than deduct the expenses for the property immediately, foregoing loss carrybacks, or even paying some expenses after the close of the tax year. It may also involve accelerating the receipt of income or gains to earlier years.

Taxpayer May Deduct Taxes for Defunct S Corp Paid in Current Year

In Brown v. Commissioner, T.C. Memo. 2017-18, the court addresses whether taxpayers can claim a deduction for taxes paid by a defunct S corporation in the current year when the taxes are owed by the corporation for prior tax years. Many taxpayers do not realize they can claim a deduction for taxes in this situation. The case also highlights the importance of clearly designating how voluntary payments are to be applied by the IRS.

The facts and procedural history are as follows:

  • The Browns owned an S corporation.
  • The S corporation:
    • incurred payroll tax liabilities for 2000 – 2002.
    • filed income tax returns for 2000 – 2002.
    • was administratively dissolved by the state in 2007.
    • did not have any business activities or assets in 2012.
  • The IRS assessed trust fund recovery penalties against the Browns for the trust fund portion of the S corporation’s payroll taxes.
  • The attorney representing the Browns remitted a check for $215,000 to the IRS with a letter indicating that the funds were to be applied the trust fund penalty.
  • The IRS applied the funds to the trust fund penalty.
  • The S corporation claimed a deduction for the payroll taxes paid in 2012 on a final tax return remitted for 2012 (The S corproation had not remitted income tax returns from 2003 through 2011).
  • The Browns then reported the flow through loss on their indivdiual income tax returns in 2012.

The IRS disallowed the deduction on the Browns’ individual income tax return. It made a number of arguments in support of disallowing the deduction.

Cash Basis Taxpayers Can Deduct Prior Taxes for Then Defunct Business

The IRS argued that the Browns could not deduct the expense as the S corporation was not a trade or business in 2012. While the business had ceased operations in 2002 and was dissolved in 2007, the court noted that the taxpayers, who were cash basis taxpayers, were able to deduct expenses in 2012 that were incurred in prior years in which the business was active. Taxpayers who pay their taxes late should take note of this rule, as this is a tax deduction many taxpayers do not know they can take.

Taxes Must be Paid by the Correct Legal Entity

The IRS also argued that the Browns could not deduct the tax payments as they were not paid by the S corporation. It isn’t described in the facts above, but the Browns had another S corporation and it remitted the funds to the attorney, who in turn remitted the funds to the IRS to pay the taxes. The Browns no doubt paid the taxes this way because the defunct S corporation at issue here did not have its own checking account. The Browns argued that this was intended to be a contribution to the defunct S corporation. The court agreed with the IRS on this issue, nothing that the payment did not originate from the correct S corporation and therefore no flow through deduction was allowed from that S corporation. The court disallowed the deduction on this basis.

Taxes are Deductible, Trust Fund Penalties are Not Deductible

The IRS also argued that the Browns could not deduct the tax payments as payments for penalties are not deductible. The Browns countered by citing the letter from their attorney that accompanied the payment to the IRS, which did not make it clear whether the payment was for the S corporation’s liability or the Browns’ personal liability for the trust fund penalties. The law says that the taxpayer is able to designate how the IRS is to apply voluntary payments like the payment at issue here. If the taxpayer had clearly designated the payment to the S corporation’s employment tax liabilities, the taxpayer may have been able to deduct the taxes (ignoring the payment originating from the wrong legal entity, described above). The court read the letter to say that the funds were to pay the penalties, not the S corporation’s liability. Since penalties are not deductible, the court did not allow the deduction.

Court Says No Reasonable Cause Defense for Trust Fund Penalty

Court Says No Reasonable Cause Defense for Trust Fund Penalty

In United States v. Liddle, Case No. 14-cv-04761-BLF (N.D. Cali. 2017), the court considered a trust fund recovery penalty case. The penalty was imposed on a CEO who admitted that his company failed to pay its employment taxes. The only question was whether reasonable cause is a defense to trust fund recovery penalties.

Businesses must withhold employment taxes from wages paid to their employees. If they do not pay the withholdings over to the IRS, the IRS may assess a trust fund recovery penalty against the responsible persons. The responsible persons include anyone who has authority or power to determine who the businesses pay. The trust fund recovery penalty is a individual obligation owed by the responsible person, not the business.

To be responsible, the responsible person must have acted willfully. The term willfulness has been defined as a voluntary, conscious and intentional act to prefer other creditors over the United States. As noted by the court, courts in other Circuits have concluded that reasonable cause can show that the person did not act willfully and, as such, reasonable cause can be a defense to trust fund recovery penalties. The court cited opinions from the Fifth, Tenth and Second Circuit Courts for this. The court went on to note that the Ninth Circuit, whose law applied in this case, did not provide for such a defense.

Because the taxpayer agreed that the other elements were satisfied in this case, the court concluded that he was liable for the trust fund recovery penalties.

The Ninth Circuit law applies to taxpayers located in California, Arizona, New Mexico, Nevada, Idaho, Washington, Oregon, and Montana. The Fifth Circuit includes Texas, Louisiana, and Mississippi. The Tenth Circuit includes Colorado, Kansas, New Mexico, Oklahoma, Utah and Wyoming. The Second Circuit includes New York, Connecticut, and Vermont.

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