The IRS’s New Appeals Arbitration Program

The Irs’s New Appeals Arbitration Program

The IRS Office of Appeals provides a great forum for resolving IRS tax disputes.  While appeals settles a lot of cases, it doesn’t settle them all.  This is where the IRS arbitration program comes in.  It is for those close cases that almost settled, but didn’t.  The IRS recently released Revenue Procedure 2006-44, which sets out…

Tax Attorney Contests IRS Bypass Letter

Texas Tax Attorney Contests Irs Bypass Letter

A taxpayer is entitled to hire a licensed attorney, CPA, or enrolled agent to represent them before the IRS. The taxpayer has a fundamental right to choose their tax advisor. The IRS generally has to accept this choice and work with the tax advisor. The IRS cannot simply ignore the tax advisor. Even to communicate…

IRS Recalculation Doesn’t Justify Abating Interest

Recent Texas Tax Case Is An Example Of Why Taxpayers Should Hire A Tax Attorney

Taxpayers may sometimes request the IRS to recalculate their tax liability, and the IRS may grant such a request, but this does not necessarily mean that the IRS accepts all the tax positions set out or omitted from the return. If the IRS subsequently recalculates the amount of tax due again and increases the amount…

Taxpayer Statements During Audit Admissible in Criminal Trial

When a civil tax case involves suspected criminal activity, the IRS conducts an initial investigation as part of an audit and may refer the case to the Department of Justice. Even when clear evidence of tax fraud has been obtained, the IRS revenue agent conducting the civil audit may continue to request information from the…