A recent spate of mail thefts has left the IRS holding the bag when taxpayer refunds have failed to reach those taxpayers. Congress has begun looking into these thefts. Some have occurred from USPS employee theft, but others...more
Back in 2005 when I was a trial attorney at the United States Department of Justice, I worked to enforce the John Doe summons on PayPal, Inc. in the federal district court in the Northern District of California, which summons...more
The National Taxpayer Advocate recently issued her Fiscal Year 2020 Objectives Report to Congress, reviewing the successes and challenges of the 2021 federal tax filing year and highlighting a series of objectives and...more
In a News Release yesterday afternoon, the IRS confirmed that the tax filing and payment deadline of July 15 will not be further extended. (In a March News Release, the IRS had previously extended the April 15 filing deadline...more
In News Release 2020-130 issued yesterday, the IRS Office of Chief Counsel announced a time-limited settlement offer for certain taxpayers with pending docketed Tax Court cases involving syndicated conservation easement...more
The Internal Revenue Regulations provide for a defense from the 20% negligence penalty imposed under Section 6662(a) of the Internal Revenue Code only where the taxpayer’s “return position is reasonably based on one or more...more
Internal Revenue Service (IRS) Commissioner Chuck Rettig has announced the People First Initiative to provide immediate relief to taxpayers, noting that "We are temporarily adjusting our processes to help people and...more
In an Internal Revenue Service (IRS) interim guidance memorandum authored by Sunita Lough, Deputy Commissioner, Services and Enforcement, the IRS has temporarily approved the acceptance of “signature images” and “digital...more
4/1/2020
/ Coronavirus/COVID-19 ,
Electronic Filing ,
Electronically Stored Information ,
Federal Taxes ,
Filing Deadlines ,
Filing Requirements ,
Income Taxes ,
IRS ,
Relief Measures ,
Required Forms ,
Tax Returns ,
U.S. Treasury
In an internal agency-wide email from Internal Revenue Service (IRS) Human Capital Officer Robin Bailey, Jr., beginning March 30th all employees—but for those in “mission-critical duties”—were instructed to evacuate the work...more
On July 1, 2019, President Trump signed the Taxpayer First Act (“Act”), which includes a host of important expanded taxpayer protections ranging from adjustments to criminal tax seizures, to John Doe summonses, to the...more
The Internal Revenue Service has had a long-standing practice of providing taxpayers with potential criminal exposure a means to come into compliance with the law and potentially avoid criminal prosecution through the making...more
In a battle of competing statutes, the First Circuit Court of Appeals has held that the IRS’s good faith belief that it had a right to collect debts discharged in bankruptcy because the debtor had filed a fraudulent return or...more
6/19/2018
/ Adversary Proceedings ,
Automatic Stay ,
Bankruptcy Court ,
Creditors ,
Debt Collection ,
Debtors ,
Dischargeable Debts ,
IRS ,
Settlement Violations ,
Tax Evasion ,
Tax Fraud
In Notice 2018-54, the IRS has notified taxpayers that proposed regulations are forthcoming which will deny state attempts to convert a taxpayer’s state and local tax obligations to a charitable deduction in order to avoid...more
5/25/2018
/ Charitable Deductions ,
IRS ,
Regulatory Agenda ,
State and Local Government ,
State Taxes ,
Substance Over Form Rule ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Liability ,
Tax Reform ,
Trump Administration
Under the new Section 7345 of the Internal Revenue Code coming into effect in January 2018, Congress has given the IRS the power to “certify” the names of delinquent taxpayers to the State Department for purposes of denying...more
11/2/2017
/ Burden of Proof ,
Certifications ,
Debtors ,
Foreign Taxpayers ,
Free Speech ,
Internal Revenue Code (IRC) ,
International Travel ,
IRS ,
Magna Carta ,
Passports ,
Tax Court ,
Travel Ban ,
US State Departments