IRS Audits Tax Procedure

Lost IRS Notice Was Timely, Despite IRS Not Following Procedures

There are a number of dates that must be met when it comes to taxes. Many of these dates are triggered by some action by the IRS. This raises the question as to what happens if the taxpayer is not aware that the IRS took the action and the IRS destroys the primary evidence that […]

IRS Audits Tax Procedure

TIGTA Questions IRS’s Future State Reorganization

IRS has the power to decide who gets what, when, and how when it comes to federal taxes. Many of these decisions are made by IRS employees as part of examining tax returns. This is why we are all watching the IRS reorganize its audit function. The Treasury Inspector General for Tax Administration (“TIGTA”) recently […]

IRS Debts Tax Procedure

How People and the Tax System Impact Individual Cases

In tax, we spend a lot of time focusing on tax rules. But tax rules only go so far. The results in tax cases are impacted by the people who work tax cases as much as they are by the tax rules. Our system of tax administration also plays a role. This is hard to […]

IRS Debts Tax Procedure

IRS Budget Constraints Continue to Make Resolving Cases Difficult

The IRS’s budget constraints have made it more difficult for taxpayers to resolve IRS tax debt problems. This is especially true for the work that it has shifted to IRS service centers to be worked remotely. The Wang v. Commissioner, T.C. Memo. 2016-123, case provides an example of this. Facts & Procedural History  Mr. Wang […]

Tax Litigation Tax Procedure

IRS Tax Attorneys Realign Organization Structure

The IRS Office of Chief Counsel employs the IRS’s own tax attorneys.  These attorneys handle most of the civil tax court matters for the IRS.  The IRS released IRS Office of Chief Counsel Notice CC-2007-012 which says that the Procedure and Administration Section of the Office of Chief Counsel subsidiary legal divisions have been reorganized into […]