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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About: Ronald Marini
Recent Posts by Ronald Marini
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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IRS to Start Passport Revocation for Seriously Delinquent Taxpayers
The IRS published on its website, Update on Passport Certifications and Taxpayer Advocate Service, that it is stopping its temporary program under which it wasn't certifying taxpayers for passport revocation etc., if the taxpayer had delinquent tax debt but also had an open Taxpayer Advocate Service (TAS) case.On September 9, 2019 we posted, IRS to Temporarily Stop…
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