Improper determination of taxpayer’s ability to pay tax liability was an abuse of IRS’s discretion
Campbell, TC Memo 2019-4 The Tax Court has concluded that IRS’s determination to sustain the proposed levy action regarding the …
Second Circuit denies taxpayer’s NOL carrybacks
Silipigno v. U.S., (CA2 1/30/2019) 123 AFTR 2d ¶2019-392 The Court of Appeals for the Second Circuit, affirming a district court, …
Tax Court thwarts use of Rule 155 to raise new issues
Vento, et al, (2019) 152 TC No. 1 The Tax Court has held that taxpayers couldn’t use Tax Court Rule …
IRS issues FAQs on shutdown’s effect on audits, collections and Tax Court operations
IRS webpage—IRS Activities Following the Shutdown IRS has issued information, in frequently asked question (FAQ) format, about the effect of …
White House to seek big domestic spending cuts; budget will be late
By David Shepardson, Sandra Maler and David Gregorio WASHINGTON (Reuters) – The White House will propose significant non-defense spending cuts …
IRS will change Form 1040, etc. instructions to reflect new Sec. 199A regs
IRS website—Instructional changes do to issuance of final regs for Qualified Business Income Deduction On its website, IRS has announced …
IRS announces on-time tax season opening and projected refund dates
IR 2019-7, 1/28/2019 IRS has announced that it successfully opened the 2019 tax-filing season on Monday, Jan. 28, 2019, as …
As we enter tax season, these extenders haven’t been extended
Joint Committee on Taxation: List of Expiring Federal Tax Provisions 2017-2027 Legislation to extend “extenders,” i.e. tax provisions with termination …
CFO was liable for the trust fund recovery penalty
McClendon v. U.S., (DC TX 1/22/2019) 123 AFTR 2d ¶2019-363 A district court, granting IRS’s motion for summary judgment, has concluded …
Eleventh Circuit analyzed estate tax lien under Supreme Court’s Summerlin principle
Saccullo v. U.S., (CA11 1/11/2019) 123 AFTR 2d 2019-344 The Court of Appeals for the Eleventh Circuit, reversing and remanding …