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 in the federal courts, classified by the types of taxpayer affected. Through analysis of these issues, the National Taxpayer Advocate [...]
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03 Mar 2011 / Back Taxes, Blog Posts, IRS Procedure, Penalties, Tax Court
Tags: collection due process, irs penalties, irs summons, quash summons, tax controversy, Tax Court, tax defense, tax litigation, tax penalties
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03 Feb 2011 / Blog Posts, Tax Court
Did you ever wonder why the IRS prevails in trials before the United States Tax Court in 9 out of 10 cases. The more paranoid among attribute the government’s lopsided success rate to a silent conspiracy between the Court and the government. But the truth is more benign. More than 80% of all Tax Court cases [...]
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Tags: IRS appeals, IRS Audits, irs disputes, tax attorney, tax audits, Tax Court, tax lawyer
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05 Jan 2011 / IRS Audits, Literature and Law, Tax Tutorials
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 [...]
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Tags: 90 day letter, IRS appeals, irs audit, notice of deficiency, tax appeal, tax audit, Tax Court
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12 Feb 2009 / IRS Audits
If you have received a notice that the IRS wants to audit your tax returns, contact us for a free assessment of your areas of risk. If you choose to hire our firm to represent you in connection with an IRS audit, here is how we begin the process: What We Need from You Before [...]
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Tags: audit representation, IRS appeals, irs audit, tax appeals, tax audit, Tax Court
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06 Feb 2009 / Tax Tutorials, Taxpayer Rights
The IRS has immense power to take away your property and/or prosecute you for tax fraud, evasion or the willful failure to file a tax return. This power, however, is not unlimited. If you listen to the myths and stories circulating among taxpayers, it is understandable that some Americans believe they have no rights when [...]
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Tags: IRS lawsuits, right to legal representation, sue the IRS, Tax Court, Taxpayer Rights