IRS Has the Burden of Proof for Items of Income

In tax disputes between taxpayers and the IRS, the burden of proof lies with the IRS to prove that a taxpayer earned more income than reported. The IRS has to have some evidence. These rules are set out in Section 7491, which shifts the burden of proof to the IRS, making it more difficult for…

The IRS’s Strategic Litigation Approach: One Case at a Time

Should The Irs Be Able To Rewrite Tax Laws That It Doesn’t Agree With?

In the complex landscape of tax law, the IRS plays a significant role in shaping and enforcing tax laws and regulations. One of the key strategies employed by the IRS is the careful selection of cases to litigate, particularly when previous decisions have favored taxpayers. By patiently waiting for the right set of facts to…

New Offer in Compromise Legislation

New Offer In Compromise Legislation

As discussed in a previous post, Congress has been toying with making changes to the IRS offer-in-compromise program. These changes were eventually included in the “Tax Increase Prevention and Reconciliation Act,” which President Bush signed into law on May 17, 2006. The new rules apply to offers in compromise filed 60 days after the date…

U.S. Tax Court Violates It’s Own Rules

Supreme Court Questions U.s. Tax Court’s Rule Violations

Do you know the feeling when you realize you are in a situation and you have no real remedy? If so, you probably also know the same feeling when you are in a situation where you are 100% right and there is a third party who is not. Most of us learn about these feelings…

Tax Liability Review by Tax Court Limited

The collection due process hearing law has provided taxpayers with another avenue for challenging their underlying tax liabilities. With this option, taxpayers can let the IRS assess the additional tax or penalties and then wait for the IRS to attempt enforced collection for the balance. They can then file a collection due process hearing request…