Resources

For years, the IRS has offered alternative dispute resolution (ADR) at various stages of the tax administrative process. Use of ADR, however, has been declining in recent years. With this new office, IRS Appeals aims to make...

When the IRS issues a Notice of Deficiency (NOD), I.R.C. Sections 6212(a) and (b)(1) require that the NOD be sent to the taxpayer’s “last known address” by certified or registered mail. The taxpayer’s last known...

When the IRS proposes changes to a taxpayer’s return that result in an underpayment of tax, it will always consider penalties under Internal Revenue Code § 6662 – Imposition of Accuracy-Related Penalty on...

In grand finale style, the IRS released its last entry to its 2024 Dirty Dozen List with a catch-all listing of transactions and invitation to taxpayers to be a whistleblower. The IRS wrapped up its 2024 Dirty Dozen list with...

A business that has employees is required by the Internal Revenue Code to withhold payroll taxes and income taxes from the wages of its employees and to pay those withheld amounts, called trust fund taxes, to the IRS....