Litigating the Merits of a Trust Fund Recovery Penalty Case in CDP When the...
In Mason v. Commissioner the Tax Court issued a regular opinion as it decided for the first time the impact of taxpayer’s failure to receive her notice of the trust fund recovery penalty (TFRP)...
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Summary Opinions for 12/14/2014
Merry Christmas, Happy (last day of) Hanaukka, Joyous Holidays and a wonderful Festivus for the restofus. A quick note on posting; we probably will not have regular substantive content up over the next...
View ArticleTrust Fund Recovery Penalty Collection Not Stopped by Installment Agreement...
In Kirkpatrick v. Commission the Tax Court addressed the case of an individual responsible officer. His corporation, Accurate, failed to pay over employment taxes for several quarters. It had a...
View ArticleDeciding Whether to Pursue a Liability – The Differing Standard between Trust...
As we have mentioned before, Les, Steve and I are engaged in updating IRS Practice and Procedure by Saltzman and Book. Last year I wrote a number of posts on Collection Due Process as I prepared to...
View ArticleSummary Opinions for May, part 1
May got away from me, and so has much of June. I’ll post the Summary Opinions for May in two parts, and handle June in the same manner. Below are some of the tax procedure items in May that we didn’t...
View ArticleSummary Opinions for July
Here we go with some of the tax procedures from July that we didn’t otherwise cover. This is fairly long, but a lot of important cases and other materials. Definitely worth a review. read more......
View ArticleSummary Opinions for October 19th through the 30th
Happy Thanksgiving Week! And thank you all for reading, commenting and guest posting! SumOp this week is full of great tax procedure content that was released or published in the end of October,...
View ArticleImproving Payroll Tax Compliance
On December 8, 2015, the IRS announced a “New Early Interaction Initiative [that] Will Help Employers Stay Current with Their Payroll.” I am not sure how the resource strapped IRS will accomplish the...
View ArticleThe Eleventh Circuit Requires IRS to Hold a Hearing Prior to Making a Trust...
Reversing the decision of the Tax Court in a Collection Due Process (CDP) hearing challenging the appropriateness of the assessment, the Eleventh Circuit in Romano-Murphy v. Commissioner determines...
View ArticleClik here to view.
Summary Opinions for 12/14/2014
Merry Christmas, Happy (last day of) Hanaukka, Joyous Holidays and a wonderful Festivus for the restofus. A quick note on posting; we probably will not have regular substantive content up over the next...
View ArticleTrust Fund Recovery Penalty Collection Not Stopped by Installment Agreement...
In Kirkpatrick v. Commission the Tax Court addressed the case of an individual responsible officer. His corporation, Accurate, failed to pay over employment taxes for several quarters. It had a...
View ArticleDeciding Whether to Pursue a Liability – The Differing Standard between Trust...
As we have mentioned before, Les, Steve and I are engaged in updating IRS Practice and Procedure by Saltzman and Book. Last year I wrote a number of posts on Collection Due Process as I prepared to...
View ArticleSummary Opinions for May, part 1
May got away from me, and so has much of June. I’ll post the Summary Opinions for May in two parts, and handle June in the same manner. Below are some of the tax procedure items in May that we didn’t...
View ArticleSummary Opinions for July
Here we go with some of the tax procedures from July that we didn’t otherwise cover. This is fairly long, but a lot of important cases and other materials. Definitely worth a review. read more......
View ArticleSummary Opinions for October 19th through the 30th
Happy Thanksgiving Week! And thank you all for reading, commenting and guest posting! SumOp this week is full of great tax procedure content that was released or published in the end of October,...
View ArticleImproving Payroll Tax Compliance
On December 8, 2015, the IRS announced a “New Early Interaction Initiative [that] Will Help Employers Stay Current with Their Payroll.” I am not sure how the resource strapped IRS will accomplish the...
View ArticleThe Eleventh Circuit Requires IRS to Hold a Hearing Prior to Making a Trust...
Reversing the decision of the Tax Court in a Collection Due Process (CDP) hearing challenging the appropriateness of the assessment, the Eleventh Circuit in Romano-Murphy v. Commissioner determines...
View ArticleSummary Opinions — Catch Up Part 1
Playing a little catch up here, and covering some items from the beginning of the year. I got a little held up working on a new chapter for SaltzBook, and a supplement update for the same. Both are...
View ArticleReport on Trust Fund Recovery Penalty Procedures
The Treasury Inspector General for Tax Administration (TIGTA) issued a report on June 30, 2016, detailing IRS procedures for processing trust fund recovery penalty (TFRP) cases. The report contains...
View ArticleFast Track Mediation for Collection
In Rev. Proc. 2016-57 the IRS announced a new fast track mediation specifically designed for collection cases (FTMC). The program will allow taxpayers with issues in offer in compromise (OIC) cases...
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