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Posts tagged "appeals"

IRS Office of Appeals Begins Virtual Conference Pilot Program

The Internal Revenue Service (IRS) is launching a pilot program to offer a web-based virtual conference option for taxpayers and their representatives in Appeals cases. The Office of Appeals hears over 100,000 cases each year for taxpayers who would like to resolve their tax disputes outside the Tax Court, and is hoping this new program will be a convenient, efficient, and flexible way to address the needs of taxpayers, particularly those who live far from an IRS Appeals office.

Tenth Circuit holds that late-filed tax returns are not "returns" for purposes of dischargeability in bankruptcy

Earlier this week the Tenth Circuit Court of Appeals issued an opinion in Mallo v. IRS, holding that certain income tax liabilities were not discharged in bankruptcy because the taxpayers filed late returns after the IRS had already assessed the taxes. Mallo v. IRS, No. 13-1464 (10th Cir. 2014). The issue in that case was whether or not those late tax returns should count as "returns" for dischargeability purposes.

Ninth Circuit affirms Tax Court judgment that OPIS tax shelter transaction lacked economic substance

On Friday, the Ninth Circuit Court of Appeals affirmed the Tax Court's decision to disallow a capital loss deduction on the ground that the underlying transaction lacked economic substance and was designed to create substantial capital losses. Reddam v. Commissioner, No. 12-72135 (9th Cir. Jun. 13, 2014).

Court of Appeals holds that the IRS does not have the authority to regulate tax return preparers

On Tuesday the U.S. Court of Appeals for the District of Columbia Circuit found that the IRS had exceeded its statutory authority when it attempted to regulate tax return preparers. Loving v. Internal Revenue Service, No. 13-5061 (Feb. 11, 2014).

Fourth Circuit finds Fifth Amendment privilege inapplicable to documents required to be maintained under the Bank Secrecy Act

Last Friday, the Fourth Circuit Court of Appeals affirmed a district court's refusal to quash subpoenas related to foreign bank account records that were required to be maintained under the Bank Secrecy Act and Treasury Regulations.

Tax Court Rejects IRS Interpretation of Accuracy-Related Penalty Calculation

Earlier this week the U.S. Tax Court issued a court-reviewed opinion finding that the IRS has been improperly calculating accuracy-related penalties in certain cases involving refundable credits (i.e., the earned income credit, the additional child tax credit, and the recovery rebate credit). Rand v. Commissioner, 141 T.C. No. 12.

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