In 2019, Congress introduced Internal Revenue Code Section 7803(e) that codified the IRS Independent Office of Appeals (Appeals) as an administrative avenue for resolving disputes without going to court, focusing on...more
More than 25 years ago, Congress enacted Internal Revenue Code Section 6751(b) to protect taxpayers from the IRS using penalties as a bargaining chip in an effort to coerce taxpayers to settle. Generally, Section 6751(b)...more