Saturday, August 17, 2013

Practitioner Warns of IRS Letters and Notices to Not Ignore (8/17/13)

Edward M. Robbins, Jr., a prominent tax litigator (see bio page here), has posted a good series of articles on six IRS Letters and Notices You Must Not Ignore.  The articles present a good summary of the problems encountered in ignoring these letters and notices; or, to state it differently, the reasons you should pay attention to these letters and notices.  This articles are on a blog sponsored by the law firm of Hochman, Salkin, Rettig, Toscher & Perez, P.C, here, which has a strong team in tax controversy matters. Readers might also want to review that firm's publications web site, here.

Ed's list is:
  1. Statutory Notice of Deficiency (Ninety Day Letter).
  2. Final Partnership Administrative Adjustment (FPAA) under TEFRA.
  3. The IRS Summons (including an IRS caused Grand Jury Subpoena).
  4. The Final Notice Before Levy.
  5. Statutory Notice of Denial of a Claim for Refund.
  6. Notice of Computational Adjustment under TEFRA.
The series of articles is:
  1. Six IRS Letters and Notices You Must Not Ignore (Tax Controversy (Civil & Criminal) Report 7/7/13), here, addressing items 1 and 2 on his list.
  2. Part II – Six IRS Letters and Notices You Must Not Ignore (Tax Controversy (Civil & Criminal) Report 8/5/13), here, addressing items 3 and 4 on his list.
  3. I will post the link to the final article when he posts it.

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