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Questions for a Frivolous Penalty CDP Hearing

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...

Applying for a Frivolous Penalty CDP Hearing

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...