Topic
Tax Procedure
12 published works
Tax Controversy Report
Tax Court Holds BBA Partnership Petition Filing Deadline Is Not Jurisdictional
By Adam Young
In Big Apple Tompkins Realty LLC v. Commissioner, the Tax Court addressed a question of first impression: whether I.R.C. § 6234(a)’s 90-day petition filing deadline for partnerships subject to the…
Dollars & Sense
When Taxpayer and IRS Can’t Agree, the Tax Court Must Intervene
On remand for re-calculation of 4 errors in deficiency amounts, concerning years 2003, 2004, 2005, and 2006, the Tax Court entered final revised decisions based on the Commissioner’s twice-revised Rule…
Agricultural Law and Taxation Blog
The “Almost Top Ten” (Part 4) – Tax Developments
OverviewToday’s article is the fourth in a series discussing what I view of significant developments in 2021 that weren’t quite big enough to make my “Top Ten” list. This time…
The Public Finance Tax Blog
Telephonic TEFRA hearings are now available through March 31, 2022
On November 4, 2020, we all thought that the COVID-19 pandemic was going to be long over by now. We certainly did not think we were going to get so…
Arkansas Tax & Incentives Update
Summary of 2021 Arkansas Tax Procedure Legislation
Act 65 establishes a system of review of administrative rules whereby the Legislative Council reexamines agency rules and considers which rules to extend or repeal. Act 143 requires tax preparers…
Webb & Morton PLLC Blog
6751(b) Defense of IRS Penalties
By Jason Morton
If you’ve ever had an IRS penalty assessed against you, you know how distressing that can be. Here, I discuss Internal Revenue Code (IRC) section 6751(b), Procedural Requirements of IRS…
Tax Controversy 360
Weekly IRS Roundup April 20 – April 24, 2020
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 20 – April 24, 2020. Additionally, for continuing updates…
Tax Controversy 360
Corporate Tax Newsletter: Are Changes Looming Over Tax Court’s Procedure Rules?
By Andrew R. Roberson, Kevin Spencer
Our recent post on potential changes to the Tax Court’s procedure rules has been republished in the Corporate Tax Newsletter – USA by The International Law Office. See here for…
Tax Controversy 360
Are Changes Looming over the Tax Court’s Procedure Rules?
By Andrew R. Roberson, Kevin Spencer
Tax controversy practitioners are undoubtedly aware of the gradual movement over the years to conform certain Tax Court procedure rules (Tax Court Rules) to those of the Federal Rules of…
Tax Controversy 360
Court Opinions – A Year In Review
Several notable court opinions were issued 2016 dealing with a variety of substantive and procedural matters. In our previous post – Tax Controversy 360 Year in Review: Court Procedure and…