Tee Time on Taxpayers’ Dime: IRS Employee Golfing on the Job

The IRS cannot simply terminate employees as private-sector employers can. IRS employees are often shielded by complex bureaucratic processes that makes it difficult to remove them from their positions. The recent case of Sheiman v. Department of the Treasury, No. 2022-2045 (Fed. Cir. 2024), provides an opportunity to consider the IRS’s challenges in terminating an……

About “Sandbagging” in Tax Litigation

The litigation process requires parties to adhere to various procedural rules. These rules are intended to ensure fairness and efficiency in the court process. One of the most critical aspects of this process is the discovery phase, where parties exchange information and evidence relevant to the case. Some litigants may attempt to gain an unfair……

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……

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