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New Rules in the United States Tax Court
By on December 6, 2018
The Tax Court has recently adopted amendments to its Rules of Practice and Procedure. These amendments come more than two years after the Tax Court proposed amendments to its rules to accommodate electronic filing of petitions and other documents. Pursuant to the new amendments to its rules, the Tax Court will soon allow electronic filing of Tax Court petitions and other documents. (The Tax Court will provide detailed information regarding the implementation of electronic filing on its website once the Tax Court is ready for electronic filing.) Under the new rules, if a Tax Court petition is filed electronically, an original signature is no longer required from the taxpayer or the taxpayer's representative.
IRS Revises Voluntary Disclosure Practice
By on December 4, 2018
On November 20th, the IRS issued Memorandum LB&I-09-1118-014 updating the process for both domestic and foreign voluntary disclosures. The IRS voluntary disclosure program is found in section 9.5.11.9 of the Internal Revenue Manual and is a long standing practice of the IRS to provide taxpayers who have potential criminal exposure a means to come into compliance with the law and potentially avoid criminal prosecution. In a prior blog post , we discussed the basics of the IRS voluntary disclosure program.
