I continue to hear a number of financial planners, accountants and even attorneys say, “Don’t name a trust as the beneficiary of an IRA. ” The rationale is that naming individuals as the IRA beneficiary is preferable because the individual …..

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In the Revenue Restructuring Act of 1998, Congress provided that taxpayers were to be provided a hearing before the IRS filed a lien or levy on taxpayer property. If filed timely, this involves a collection due process (CDP) hearing; if …..

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Judicial opinions often include sentences that misstate the law. Often these sentences will be picked up by the IRS (and sometimes even taxpayers) years later to support arguments that courts should depart from the law. For example, this quote comes …..

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I often wonder if our tax laws could be administered in a more cost-effective manner. Why is it that cases continue to come out where taxpayers have to spend years arguing about a tax debt with the IRS, only to …..

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We all make mistakes. The IRS often prosecutes taxpayers who make mistakes. On the other hand taxpayers occasionally prosecute the IRS when its employees make mistakes. This brings me to the case of Ward v. United States, a Texas Springs …..

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Our tax laws seem to evolve (devolve?) over time. This evolution seems to follow a pretty predictable pattern. I will use Action on Decision 2005-001, which is an interesting decision in and of itself, to describe this process. In this …..

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Clients often ask me whether the IRS takes steps to slant the facts and law in the governments favor. I often explain that, as with most legal matters, there is really no right or wrong answer until the court makes …..

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