The Court of Appeals for the Seventh Circuit, in Our Country Home Enterprises, Inc., (CA 7 5/3/2017) 119 AFTR 2d ¶ 2017-729, affirmed the Tax Court and agreed with similar holdings by the Fourth and Tenth Circuits, has held that a portion of Reg. § 301.6330-1(e)(3) is a reasonable interpretation of the Code. That portion…
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Offshore Tax Suit To Switch From OVDP To Streamline Doesn’t Block Collection
According to Law360, three taxpayers seeking to switch over to the IRS’ new “streamlined” compliance program for unreported offshore income argued to a D.C. Circuit panel Tuesday that their lawsuit is not foreclosed by the Anti-Injunction Act's bar on pre-enforcement tax challenges, attacking the government’s key defense in the case. The case is Maze et…
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Whistleblower Loses Challenge To Docked Reduced Whistleblower Award At Tax Court.
On December 13, 2016 we posted Treasury Releases Their Report On The IRS Whistleblower Program where we discussed that it can take from five to seven years, or more, for the IRS Whistleblower Office to make a decision about whether to pay an informant for information about individuals or businesses that don't pay all of…
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Tax Court Held That IRS Didn't Accept Taxpayers' Offer When it Cashed Their Check
The Tax Court has held, for a number of reasons, that IRS didn't accept the taxpayers' offer in compromise (OIC) when it cashed their check that accompanied the OIC and then, approximately 100 days later, refunded the taxpayers' payment. The Court also held that, where a taxpayer is a shareholder in an S corporation, the…
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