The TIGTA issued it's report on September 27, 2019 stating that the Internal Revenue Service isn’t effectively auditing corporations, despite a change in policy on how the agency was to conducts tax examinations, that was supposed to make the process more efficient. Historically, the LB&I Division has used a variety of methods to identify tax returns…
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TC Sustains IRS Denial of Face-to-Face CDP Hearing
The Tax Court has sustained in Roberts, TC Memo 2019-117 the IRS's denial of a request by married taxpayers for a face-to-face Collection Due Process (CDP) hearing. Because the taxpayers failed to participate in the originally scheduled telephone CDP hearing, the Court also sustained IRS's Notice of Intent to Levy. An IRS determination regarding a proposed collection…
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Accidental Americans Ask France to Block FATCA Reporting
A group representing French-American taxpayers said on October 3, 2019 that it had filed a suit against France with the European Commission, hoping to avoid strict US compliance rules that could see them blacklisted by French banks starting in January. The "Accidental Americans" association has been battling for years to be exempt from a US…
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TC Helds That IRS Settlement Officer Abused Discretion in Sustaining the Levy to Collect Penalties
The Tax Court has found that an IRS settlement officer (SO) abused his discretion in sustaining a proposed levy to collect unpaid trust fund recovery penalties (TFRPs) after the taxpayer's offer in compromise (OIC) had been terminated due to default. The court remanded the case for determination of whether the OIC had been properly terminated.…
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