As published in the Winter Park/Maitland Observer, Thursday Jan. 3, 2012 Edition Offers... Read More »
How to Appeal an IRS Audit
The Notice of Deficiency If you are audited and cannot come to an agreement with the examining agent, the IRS will issue what is known as a Notice of Deficiency (sometimes also called the 90 Day Letter). The Notice of Deficiency contains a calculation of the additional tax, interest and penalties the IRS believes you…
Read Full Article Categorized in: IRS Audits, Literature and Law, Tax TutorialsTax Court Update – October 2008 – Attorney Liable for Excessive Costs
Arthur G. Krol v. Commissioner – An experienced tax attorney was held liable under Internal Revenue Code section 6673(a)(2)(A) and ordered to pay the United States government $1,200.00 for “unreasonably and vexatiously” multiplying the proceedings by filing a tax court petition challenging his client’s tax liability after the taxpayer (and the lawyer) had already conceded that liability in…
Read Full Article Categorized in: Court CasesTax Court Update – October 2008 – The Limits of Tax Court Jurisdiction
Joseph B. Williams, III v. Commissioner of Internal Revenue – The taxpayer filed a petition seeking to prevent the IRS’s assessment of interest on certain income tax deficiencies and seeking the abatement of certain penalties imposed on the him in connection with his failure to file FBARs (Foreign Bank Account Reports). IRS counsel moved to dismiss each…
Read Full Article Categorized in: Court Cases“Last Known Address” Rule Not Applicable to Notices of Deficiency
Generally, the IRS is required to send its notices to the taxpayer’s “last known address.” Treasury Regulation 301.6216-2 defines “last known address” as: [T]he address that appears on the taxpayer’s most recently filed and properly processed Federal tax return, unless the IRS is given clear and concise notification of a different address. On August 5th, 2008 the Tax Court,…
Read Full Article Categorized in: Court Cases, Tax Collections