In a recent decision, the U.S. District Court for the Central District of California held that the Internal Revenue Service (“IRS”) did not violate Internal Revenue Code (“IRC”) Section 7433 or related regulations when it...more
The Taxpayer First Act (“TFA”), which was signed into law on July 1, 2019, makes the most significant changes to administrative procedures since the Internal Revenue Service Restructuring and Reform Act of 1998. In addition...more
Taxpayers are required to maintain records in sufficient detail to enable the preparation of an accurate tax return. Thus, in the context of an examination, the Internal Revenue Service (“IRS”) has broad authority to examine...more
The IRS’ determinations in a notice of deficiency are generally presumed correct. Therefore, unless specifically excepted by Tax Court Rule or statute, the burden of proof in civil tax proceedings is ordinarily on the...more