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Saturday, August 31, 2013

Ed Robbin's Excellent Blog on Section 6501(c)(8) Extending the Statute of Limitations for Certain International Reporting (8/31/13)

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I encourage readers to study Ed Robbins most recent contribution to the Tax Crimes / Tax Procedure literature.  Edward Robbins,  You Should...
Saturday, August 24, 2013

JCT Staff Review of $2 Million + Refunds (8/24/13)

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I was reading today a letter to the editor of Tax Notes from Professor George K. Yin, here , formerly tax counsel to the Joint Committee on...
Friday, August 23, 2013

6-Year Return Adequate Disclosure By Reference to Other Returns (8/23/13)

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The normal statute of limitations in tax matters is 3 years from the date the return was filed.  There are exceptions.  One is the six-year ...
Monday, August 19, 2013

Restraining Taxpayers for Tax Debts (8/19/13)

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This morning, I read a recent case involving the writ ne exeat republica.  I suspect that many readers will not have heard of the writ.  Wh...

Remittance to IRS -- Is it a Payment or a Deposit? (8/19/13)

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Whether a remittance to the IRS is a payment of tax or a deposit can have significant consequences.  For example, if it is a payment of tax...
Saturday, August 17, 2013

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

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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 ...
Wednesday, August 14, 2013

The Effect of Violation of the Statutory Requirements for a Notice of Deficiency (8/15/13)

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Leslie Book has a good blog entry titled What Happens When The IRS Violates a Statutory Requirement Relating to Notices of Deficiency? (Pr...
Thursday, August 8, 2013

Cheating, Visibility and Return Preparers (8/8/13)

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A new tax procedure blog, Procedurally Taxing, here , has a new blog entry written by Professor Leslie Book, here , titled Cheating and Visi...
Tuesday, August 6, 2013

Tax Court Tanks Another Taxpayer's Bullshit Tax Shelter (8/6/13)

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This is almost ho-hum now.  At some point, I will quit posting these items.  But, for now, I post it because the Tax Court elevated it to a...
Saturday, August 3, 2013

IRS Has No Authority To Settle Cases Referred to DOJ Tax Even After They Are Returned (8/3/13)

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In United States v. Jackson , 2013 U.S. App. LEXIS 1674 (3d Cir. 2013), here .  This is a non-precedential opinion, but it has a interpretat...