IRS Can Sidestep Taxpayers’ CDP Rights by Applying Overpayments

Imagine that Congress sets out a remedy to curb IRS abuses. And further consider that after the taxpayer pursues the remedy, the rules allow the IRS to simply sidestep the remedy. So the remedy is no remedy at all. That is what we have in the Zuck v. Commissioner, No. 25125-14L (U.S.T.C. Apr. 6, 2022)……

When the IRS Comes Knocking: Addressing Tax Fraud

Tax fraud typically involves neglecting tax responsibilities, such as by not filing returns or evading tax payments, or engaging in deliberate actions to obstruct the IRS’s assessment or collection of taxes. The compliance problems that are later found to be tax fraud usually involve actions that pyramid over time. This timing issue arises as repeated……

Resolving IRS Taxes: What is “Future Income”?

When it comes to tax rules and government administrative guidance, one may expect that the provisions are clear and can be easily applied. However, this is often not the case. Even detailed regulations with explanations may fail to provide readily discernible answers. Applying such rules to common situations can still lead to questionable or incorrect……

The Unanswerable Discovery Request

Have you ever been asked a question that you should probably know the answer to, but you don’t fully know the answer or have access to information to find the actual answer? This is a frequent occurrence when it comes to litigation and, in particular, tax litigation. The litigation discovery process involves exchanging relevant information……

error: Content is protected!!