Disgorgement by Tax Preparer Denied by U.S. Federal Court

The IRS was handed a huge defeat in federal district court on Tuesday when Judge Anne B. Conway of the Middle District of Florida ruled that the United States had not proved that even $1 of profits (ill-gotten gains) received by a…

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Most Litigated Tax Issues

National Taxpayer Advocate Nina Olson has issued her annual report on the most frequently litigated tax issues: Internal Revenue Code § 7803(c)(2)(B)(ii)(X) requires the National Taxpayer Advocate to identify the ten tax issues most often litigated…

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Cheesecake Factory Takes IRS to Tax Court

Forbes reports that The Cheesecake Factory has filed a Tax Court Petition challenging an IRS deficiency assessment of $838,000: In a bit of reflux from the big Wall Street scandal involving backdated stock options, the Cheesecake…

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Tax Disputes and the Burden of Proof

Internal Revenue Code § 7491 titled Burden of Proof states in part: (a) Burden shifts where taxpayer produces credible evidence (1) General rule If, in any court proceeding, a taxpayer introduces credible evidence with respect…

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Heading to Tax Court? Here’s How to Win

With the IRS more aggressively pursuing delinquent taxpayers in an effort to close the Tax Gap, we expect to see more cases tried in Tax Court. Here is a brief primer on the peculiarities of…

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