Tag: Tax Litigation

What do you do if a loved one is under audit by the IRS and then dies before the audit is closed? Imagine that the IRS issues a Notice of Deficiency to the taxpayer. Do you have the right to petition the U.S. Tax Court for the taxpayer? The court recently addressed this in Sanders……

Justice is not a word that is often mentioned in tax cases. While justice may be handed out in the opinions, the term “justice” isn’t usually expressly stated in the opinion or in the rules that the courts go by. There are exceptions. One exception is in the rules that allow IRS attorneys to raise……

The U.S. Tax Court is unique in many ways. It has its own rules and the rules do not always comport with the rules that apply in other Federal courts. One example is that a party cannot just “non-suit” a case in tax court. A non-suit is the process of simply dismissing an action that……

There are times when the IRS pursues cases that it should not. If this happens to you and you prevail in your case, you should know that the court may order the IRS to pay your attorneys fees and costs. You usually have to make a “qualified offer” to get this type of award. The……

There are times when IRS employees violate the law. This includes intentional and negligent conduct that violates the law. Many of these violations go unreported. This is often for fear of retaliation or lack of resources. It may also be due to a belief that there is no remedy for taxpayers in this situation. The……