The shortcut assessment procedures for tax collections deemed to be in "danger" include jeopardy and termination assessments. All the relevant provisions of the Internal Revenue Code (IRC) authorizing jeopardy and termination assessments seem favorably skewed … [Read more...]
What Is A CDTFA Notice of Determination?
A Notice of Determination from the CDTFA notifies the taxpayer of an amount due to the California Department of Tax and Fee Administration. The notice will contain the amount of tax, penalty, fees, and interest due. If you do not agree with the amounts shown, you can appeal by … [Read more...]
Suit to Reduce a Tax Assessment to Judgment
Not much is written on the internet apart from the dry text of the Internal Revenue Manual about suits to reduce tax assessments to judgment. This little-known (and rarely used?) tax collection avenue is available to the IRS to effectively extend the 10-year statute of … [Read more...]
Innocent Spouse Relief: When The IRS Notifies The Non-Requesting Spouse
Once the IRS receives a taxpayer's request for innocent spouse relief, either election under 26 CFR § 1.6015-2 or equitable relief under 26 CFR § 1.6015-4, the non-requesting spouse is not left alone in the dark. The IRS must notify the non-requesting spouse of the relief … [Read more...]
Tax Penalty Abatement Due to Erroneous IRS Advice
For tax matters, we rely on experts. At times that expert is a CPA, local tax attorney, or tax preparer. However, in other instances that expert can also be an IRS representative, and just like any human being, IRS representatives make mistakes. The good thing is that taxpayers … [Read more...]
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