Did You Update Your Address With the IRS?

Houston Tax Attorney

0

The IRS relies heavily on the U.S. Postal Service to deliver notices to taxpayers. Many of these notices are received by taxpayers. This often comes up when the taxpayer has changed addresses. When the taxpayer does this and the address change is reported to the IRS, should the IRS have to update its records and […]

Is IRS Manger Approval Required for Computer Generated Penalties?

Houston Tax Attorney

0

The IRS and the courts have invalidated penalties where the IRS fails to obtain IRS manager approval before assessing the penalty. It has done so in cases where the penalties are manually assessed by IRS personnel. But what about penalties that are automatically assessed by the IRS’s computers? The court addresses this in Atl & […]

The IRS’s Math Error Powers

Houston Tax Attorney

0

With our tax system, taxpayers are generally required to file returns to tell the IRS how much tax is due. This is no easy task as the tax reporting process can be confusing. Errors happen. Congress has authorized the IRS to correct mathematical and clerical errors made on tax returns. The IRS’s CCA 129453-17 memorandum […]

Use of Accounting Board Order in Criminal Tax Case

Houston Tax Attorney

0

If an accountant is disciplined by the accounting board, can the discipline be used to increase his criminal sentence for tax fraud when the accounting board’s discipline did not prohibit or address fraud? The court addressed this in United States v. Iley, No. 17-1269 (10th Cir. 2019). Facts & Procedural History The defendant was a […]

Statements Made to IRS Special Agents

Houston Tax Attorney

0

If you are contacted by an IRS special agent for an informal meeting, can statements made during the meeting be used against you in court? The answer is “maybe.” The court addresses this in United States v. Henry, No. 2017-0001 (D. VI 2018). Facts & Procedural History The IRS criminal investigation unit received a tip […]

Innocent Spouse Relief for One’s Own Income

Houston Tax Attorney

0

While taxpayers are often aware that innocent spouse relief can eliminate their liability for tax on items of income earned by their spouse (or ex-spouse), fewer taxpayers realize that innocent spouse relief can also help with tax on income they earned themselves. The recent Heydon-Grauss v. Commissioner, T.C. Memo. 2018-209, case provides an opportunity to […]

IRS Appeals Guidance on In-Person Conferences

Houston Tax Attorney

0

The IRS Office of Appeals has been making changes to how it conducts appeals conferences.  In this past few years, these changes have made it difficult to obtain an in-person conference.  The IRS recently issued interim guidance AP-08-1118-0013 to authorize appeals to allow for more in-person conferences. About the IRS Office of Appeals The IRS […]