Proposed reliance regs on personal use of employer-provided vehicles
Preamble to Prop Reg REG-101378-19; Prop Reg §1.61-21 IRS has issued proposed regs, on which taxpayers may rely until the publication of …
Preparer penalties subject to full payment rule before district court has jurisdiction
Davis, (DC MD 8/14/2019) 124 AFTR 2d ¶2019-5143 A district court has found that Code Sec. 6694(b) preparer penalties are subject to the …
Eligible taxpayers get automatic 2018 individual taxpayer estimated tax penalty relief
IR 2019-144, 8/14/2019 In an Information Release, IRS has announced that the relief that it announced earlier this year, with …
IRS updates third-party contact notice procedures to comply with Taxpayer First Act
Interim Guidance on Third-Party Contact Notification Procedures The IRS has issued a memorandum updating its third-party contact notification procedures to …
EIC can be disallowed for two years even for partial denial in previous year
Chief Counsel Advice 201931008 In Chief Counsel Advice, the IRS has stated the earned income credit (EIC) can be disallowed …
Bankruptcy does not toll refund suit statute of limitations
Dixon, (DC IN 7/24/2019) 124 AFTR 2d ¶2019-5085 A district court has held that a taxpayer’s bankruptcy proceedings did not toll …
Tax Court upholds rejection of offer-in-compromise, denial of abatement request
Love, TC Memo 2019-92 The Tax Court has upheld the IRS’s decision to reject a taxpayer’s proposed offer-in-compromise and to decline …
Settlement Officer did not abuse her discretion in not withdrawing NFTL
Richards, TC Memo 2019-89 The Tax Court has held that a settlement officer (SO) did not abuse her discretion by sustaining …
IRS has begun sending letters to virtual currency owners advising them to pay back taxes
IR 2019-132, 7/26/2019 Information Release 2019-125 Letter 6173 Letter 6174 Letter 6177-A In an Information Release, the IRS has announced …
IRS whistleblower notifications under Taxpayer First Act
Background. IRS has the authority to reward individuals (whistleblowers) who provide it with information leading to the collection of tax, interest …