Showing posts with label appeal. Show all posts
Showing posts with label appeal. Show all posts
Sunday, April 27, 2025

The Importance of Marking A Return As “Final”

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I have worked tax controversy for many years now. I have seen the system work well; I have seen the system work poorly. I would say – with s...
Monday, July 8, 2024

An Erroneous Tax Refund Check In The Mail

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  Let’s start with the Code section: § 6532 Periods of limitation on suits. (b)  Suits by United States for recovery of erroneous refund...
Saturday, June 29, 2019

IRS Notices And Waiting To The Last Minute

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We have been fighting a penalty with the IRS for a while. What set it up was quite bland. We have a client. The business had cash ...
Sunday, May 5, 2019

I Filed A Petition With The Tax Court

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This week I put in a petition to the Tax Court. It used to be that I could go for years without this step. Granted, I have become ...
Saturday, February 2, 2019

A Rant On IRS Penalties

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I am reading that the number one most-litigated tax issue is the accuracy-related penalty, and it has been so for the last four years. ...
Thursday, August 27, 2015

Phone Call About The Statute Of Limitations

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Recently I received a call from another CPA.   He is representing in a difficult tax audit, and the IRS revenue agent has reque...
Friday, April 25, 2014

The 6707A Tax Penalty Is Outrageous

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I have attached a penalty notice to this blog. Take a look . The IRS is assessing $14,385 for the 2008 tax year, and the description gi...