Bankruptcy Tax IRS Audits Tax Procedure

The IRS Isn’t Charged With Knowledge of Other Federal Agencies

The IRS only has to mail a notice of deficiency to a taxpayer’s last known address in order to assess or record a tax liability for the taxpayer.  This “last known address” rule is often the subject of disputes.  The Sadek v. Commissioner, T.C. Memo. 2018-174, case provides an example where information available to the […]

Tax Litigation Tax Procedure

Post Office Tracking Data Can Result in Tax Disputes

Post Office Tracking Data Can Result in Tax Disputes There have been a number of tax cases involving disputes as to when tax documents are mailed to the government. In Tildon v. Commissioner, No. 15-3838 (7th Cir. 2017), the court considered a dispute that turned on whether U.S. Postal Service tracking data is a “postmark […]

IRS Penalties Tax Procedure Trust Fund Penalties

You Cannot Dodge Notice for the Trust Fund Recovery Penalty

It is almost always advisable to keep on the lookout for and open correspondence from the IRS. The Haben v. Commissioner, T.C. Summary Opinion 2015-55, case provides an example. In Haben, the U.S. Tax Court concluded that a taxpayer could not contest a trust fund recovery penalty during a collection due process hearing because he […]