Tax Law Blog | IRS Tax Attorneys
TAX LAW NEWS - TAX LITIGATION
From the category archives:
Tax penalties present taxpayers with unique issues to consider. Wilson v. Commissioner, T.C. Summary Opinion 2008-91, describes the situation where a tax attorney represents a taxpayer with a tax penalty that was imposed for a tax return prepared by the attorney’s firm. The issue that the case describes is the conflict of interest that the [...]
{ 0 comments }
Tax penalties present taxpayers with unique issues to consider. Wilson v. Commissioner, T.C. Summary Opinion 2008-91, describes the situation where a tax attorney represents a taxpayer with a tax penalty that was imposed for a tax return prepared by the attorney’s firm. The issue that the case describes is the conflict of interest that the [...]
{ 0 comments }
In these difficult economic times, repaying the IRS is becoming harder than ever. Installment agreements may be entered into in good faith, but while payments are being made, interest and penalties continue to run. Every five years, interest and penalties double the original tax. Most attempts to repay the IRS result in the amount owed [...]
{ 0 comments }
The Internal Revenue Service is adept at using leverage to intimidate, coerce and bluff taxpayers and their representatives into adverse collection and examination determinations based upon weak legal authority and incomplete or insufficient facts. The IRS will “roll-over” taxpayers and weal representatives who are not familiar with taxpayer rights and lack of knowledge about the [...]
{ 0 comments }
Tax professionals in a local tax practice (CPAs, accountants, enrolled agents, attorneys) have an inherent “conflict of interest” for aggressive representation of any one client because they do not want to antagonize the local IRS revenue officer or examiner in a way that will have a negative impact on their other clients. The IRS will [...]
{ 0 comments }
