There are more than 100 penalties in the Internal Revenue Code. Each penalty varies in scope, but a common defense for almost all of them is “reasonable cause.” Where this defense applies, the IRS can’t impose...
The IRS continues to struggle with processing and adjudicating ERC claims. Earlier today, Taxpayer Advocate published a Blog post with an update on the IRS’ progress (or lack thereof) and a call to the IRS to bring much...
Once administrative prerequisites are satisfied—namely payment of the liability, the filing of a valid refund claim, and the passage of requisite time—a taxpayer may initiate a refund lawsuit. But where and how that...
Generally, the IRS has three years to select an income tax return for audit. But if the taxpayer never files an income tax return, the three-year statute of limitations period never starts, providing the agency with unlimited...
This is the second in a series of refund litigation blog posts. In this post, I focus on requirements that must be satisfied before a taxpayer can file a refund lawsuit. These initial requirements are more than just...
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