Jack Townsend offers this blog in conjunction with his Federal Tax Procedure Books, currently in the 2019 editions (Student and Practitioner). Annual editions of the books are published in August. Those books may be downloaded from SSRN (see the page link in the top right hand column of this blog title 2019 Federal Tax Procedure Book & Updates). In addition, Jack uses this blog to discuss issues of federal tax procedure.
Monday, November 11, 2013
Isley Brother (of Isley Brothers) CDP Case Decision with Tax Procedure Issues (11/11/13)
Earlier today, I posted a blog on the Federal Tax Crimes Blog, IRS Authority to Settle After Referral to DOJ Tax (11/11/13), here. In that blog, I point readers to an excellent blog by Peter Reilly -- An Isley Brother In Tax Court - Does Tax Crime Pay (Forbes Taxes 11/10/13), here. Peter discusses the recent decision in Isley v. Commissioner, 141 T.C. No. 11 (2013), here. I refer readers to Peter's excellent discussion of the issues in the case. In my Federal Tax Crimes Blog entry, rather than re-covering the ground that Peter does so well -- I urge readers to read his blog -- I focused on one aspect of the case that particularly interested me -- the application of Section 7122(a), here, that gives DOJ authority over compromises of criminal and civil matters that have been referred to DOJ. I won't repeat my discussion here, but refer interested readers to that blog entry.
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