The IRS, like many organizations, faced significant challenges during the COVID-19 pandemic. It had to adapt to new working conditions, which led to delays in processing paperwork, including tax returns, and difficulties in responding to taxpayer inquiries. During this time, when a taxpayer could reach someone at the IRS, they were often told that due……
Tag: IRS Appeals
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)……
Late-Filed Tax Returns & Excess Collections
Life happens. We all experience it. There are times when life events can result in tax returns being filed late. Our tax laws offer little in way of leniency when this happens. The IRS will assess late filing penalties. Worse yet, amounts that were already timely paid to the IRS may not be refunded to……
Adjustments Stemming from IRS Settlements
Generally, when it comes to civil matters, state and Federal law includes various “statutes of limitations” and “discovery rules.” The statute of limitations rules say that a claim has to be filed within a certain time period. The discovery rules say that the time period for the statute starts to run when the claim is……
New IRS Appeals Procedures for Tax Controversies
The IRS administrative function plays a critical role in our tax administration system. The appeals process settles a majority of all tax disputes. It does so using processes and procedures that have developed over many years. To the uninitiated who have not experienced the IRS appeals process, the process can be confusing and, unfortunately, the……
Getting the IRS to Pay for Your Tax Attorney
An IRS audit or notice comes with a cost for the taxpayer who receives it. The cost can include additional tax, interest, and even penalties. Even if the taxpayer did everything correctly, the IRS audit or notice still comes with a cost. The cost can include the time and effort the taxpayer has to expend……
Settle Taxes & Keep Right to Dispute Open
If there is any doubt as to whether a taxpayer is liable for income taxes, there is a good chance that the IRS will agree to settle for less. The IRS Office of Appeals is tasked with doing just that. IRS appeals settlements are usually all or nothing. If the taxpayer does not accept the……
How to Contest an IRS Settlement Agreement
What happens if the IRS enters into a settlement agreement for your tax liability and then, later, it takes a position that is inconsistent with the agreement? For example, can the IRS agree that an expense is deductible by your business only to say that the same is expense is taxable income to you as……