The IRS may no longer penalize courtesy copies of frivolous returns. In recent years the IRS has become heavy handed in its application of “Frivolous Return Penalties” under I.R.C. Sec. 6702. The penalty is $5,000 for submitting a return that meets any of...
There are certain issues that the Tax Court stonewalls and refuses to address. One such issue is the meaning of the word “verification” where it appears in I.R.C. Sec. 6330(c)(1). That is the Collection Due Process (CDP) statute that informs Appeals...
In Tax Court with a CDP hearing case? You will want to read this brief. In 1998 the IRS’ collections actions had become so outrageously aggressive and lawless that even Congress realized that Americans were being abused. They passed a law that granted tax payers...
In a previous post I discussed applying for a Collections Due Process Hearing (CDPH). And emphasized that the IRS has the burden of proof concerning penalties. All you really need to do in that case is deny that you filed a frivolous document. The Service must prove...
A friend of mine, a man deeply involved with the Service, sent me an impressive package of research, law, authority, and facts to be considered in his frivolous tax return Collections Due Process hearing (CDP)[1]. He was planning to send it along with his request for...
