IRS Abuse of Discretion NC SC

Appeals & Hearings / IRS Abuse of Discretion / IRS Collection / Trust Fund Recovery Penalty / U.S. Tax Court Litigation

United States Tax Court Decision for the Week-Trust Fund Recovery Penalty & IRS Abuse of Discretion

A recent Tax Court decision was reported dealing with Trust Fund Recovery Penalty and IRS Abuse of Discretion.  J.  Frank Best, Certified Public Accountant and United States Tax Court Litigator in…

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April 22, 2018

Appeals & Hearings / IRS Collection / IRS Problems / Non-Filers & Delinquent / Tax Audits / U.S. Tax Court Litigation

United States Tax Court Decision for the Week – You be the Judge

IRS Fails to Prove Fraudulent Intent; Fraud Penalties Inapplicable The United States Tax Court held that the IRS failed to prove a couple's fraudulent intent in underpaying their taxes, and…

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June 5, 2016

Appeals & Hearings / IRS Collection / IRS Problems / Non-Filers & Delinquent / Tax Audits / U.S. Tax Court Litigation

United States Tax Court Decision for the Week – You be the Judge

Accountant's Law School Tuition Was Not a Deductible Expense The United States Tax Court, declining to reconsider the validity of reg.section 1.162-5(b)(1), held that an accountant who prepared returns and…

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May 25, 2016

Appeals & Hearings / IRS Collection / IRS Problems / Non-Filers & Delinquent / Tax Audits / U.S. Tax Court Litigation

United States Tax Court Decision for the Week – You be the Judge

No Abuse of Discretion by Settlement Officer; the IRS Levy is Sustained The United States Tax Court sustained a proposed levy action against an individual who claimed her 1991 bankruptcy…

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May 9, 2016

Appeals & Hearings / IRS Collection / IRS Problems / Non-Filers & Delinquent / Tax Audits / U.S. Tax Court Litigation

United States Tax Court Decision for the Week – You be the Judge

Expiration of Statute of Limitations Period Prevents IRS Collection of Tax Debt The United States Tax Court held that the IRS can't collect an individual's unpaid taxes because the statute…

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March 23, 2016

Appeals & Hearings / IRS Collection / IRS Problems / Non-Filers & Delinquent / Tax Audits / U.S. Tax Court Litigation

United States Tax Court Decision for the Week – You be the Judge

United States Tax Court Sustains Lien and Levy to Collect Company's Unpaid Employment Taxes The United States Tax Court held that the IRS Appeals Office did not abuse its discretion…

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February 21, 2016

Appeals & Hearings / IRS Collection / IRS Problems / Non-Filers & Delinquent / Tax Audits / U.S. Tax Court Litigation

United States Tax Court Decision for the Week – You be the Judge

No IRS Abuse of Discretion in Upholding Notice of Federal Tax Lien Filing The  United States Tax Court held that the Appeals Office did not abuse its discretion when it issued a…

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January 13, 2016

Appeals & Hearings / IRS Collection / IRS Problems / Non-Filers & Delinquent / Tax Audits / U.S. Tax Court Litigation

United States Tax Court Decision for the Week – You be the Judge

The United States Tax Court Held No IRS Abuse of Discretion in Sustaining Federal Tax Lien Filing The Tax Court held that a settlement officer in the IRS Appeals Office…

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December 8, 2015

Appeals & Hearings / IRS Collection / IRS Problems / Non-Filers & Delinquent / Tax Audits / U.S. Tax Court Litigation

United States Tax Court Decision for the Week – You be the Judge

The United States Tax Court Dismisses Untimely Petition Challenging Collection The Tax Court dismissed for lack of jurisdiction a couple's petition challenging a collection determination, finding that it wasn't filed…

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November 22, 2015