by Stephen G. Salley and Anthony J. Scaletta Click here for the original, which appeared in the Fall 2003 issue of the Florida Bar Journal. As part of the Internal Revenue Service Restructuring and Reform Act of 1998, Congress enacted new Internal Revenue Code...
Tax Court ruled that IRS Appeals officers must verify that a proper assessment was made in a CDP hearing. Even if the taxpayer doesn’t raise the issue until he is in Tax Court, the IRS must verify the assessment. This is the Case: Hoyle v. Commissioner, 131 T.C....
The following is a Google Books preview of “A Practical Guide to Federal Evidence” by Bocchino and Sonenshein. It is searchable. I don’t know if it is available for sale or if it is complete in this preview. But it offers a handy summary of the...
By Pablo Rodriquez, The Tax Return Team Was Mr. Hendrickson a “person” pursuant to 26 U.S.C. § 7343 who could be charged with a criminal penalty? What about Irwin Schiff, Lindsey Springer, Larkin Rose, Cynthia Lynn Neun, Walter Allen Thompson, Bonita Lynn...
I’ll start with the bad news. The U.S. Tax Court is not a fair venue to litigate the limited application or proper enforcement of the income tax laws. The court vigorously suppresses any suggestion that there are limits to IRS authority or that the IRS might be...
TAX COURT HISTORY began when Congress created the “U.S. Board of Tax Appeals” in the Revenue Act of 1924. The Board consisted of “members” whose job it was to make decisions in tax disputes. The members selected one of their own as “chairman” every two...
TAX COURT JURISDICTION is defined by statute. There are a number of areas over which the court has jurisdiction. Chief among them are: deficiencies, overpayments,[1] interest abatement,[2] wrongfully collected amounts,[3] innocent spouse relief,[4] and worker...
There are some important differences in how cases are conducted in Tax Court as opposed to state and federal district courts. In disputes over money or property in a state or district court, the creditor must sue the debtor and place evidence of the alleged debt...
