What “Authority” for Accountant Nullifies the Disability Exception for Tax Refunds?

Deadlines are a central feature of our tax system. We have written about many of these various deadlines on this website. From deadlines for filing returns, deadlines for various tax elections, to deadlines for filing appeals from audits, to deadlines for filing collection actions, deadlines for appeling IRS audits, and even tax court and other……

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COVID-19 Extended Tax Deadlines Longer Than Many Realized

Taxpayers have various tax filing deadlines throughout the year. Missing one can trigger penalties, interest charges, and collection actions. When there is a major disaster, the IRS typically grants short extensions to give affected taxpayers breathing room. During the COVID-19 pandemic, the IRS issued notices extending various tax deadlines by a few months. The agency……

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You Can’t Raise What You Didn’t Know: The Variance Doctrine

Our income tax system uses a self-reporting process. Taxpayers, in most cases, voluntarily file income tax returns. The IRS can then evaluate the filings to determine whether they appear to be correct or warrant further investigation. The IRS has developed a whole regime of forms to be used for this very purpose. Taxpayers who fill……

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Substantial Variance Doctrine for Informal Tax Refund Claims

Taxpayers often submit refund claims when they discover that they overpaid their taxes. Taxpayers usually do this by submitting a formal refund claim using the IRS’s prescribed forms. But this is not always required. In many cases, taxpayers will submit so-called “informal refund claims” to the IRS during the course of an IRS audit. The……

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