Cases lacking documentation or adherence to procedural requirements or that have new taxpayer information will be returned to Examination. In September, the IRS Office of Appeals began a policy of hearing only cases that are fully developed; hearing officers will not do their own investigations and will send any new
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TOPICS / TAX
IRS practice & procedure
Jeopardy and termination assessment cases
In some circumstances, the IRS may resort to a series of procedures known as jeopardy or termination assessment and collection. If the IRS believes that the collection of an unassessed liability is in jeopardy, it may take steps to begin collection proceedings without following the normal assessment and collection procedures
Changes made to IRS streamlined offshore compliance procedures
The IRS updated its streamlined offshore compliance program to provide procedures taxpayers residing both inside and outside the United States should use to participate in the program. The streamlined offshore compliance program is for taxpayers whose failure to comply with requirements to report offshore assets is nonwillful. It is designed
CPA practitioners sue to stop PTIN fees
Two CPAs have filed suit in the U.S. district court for the District of Columbia, asking the court to stop the IRS from charging fees for issuing preparer tax identification numbers (PTINs), to obtain refunds of fees paid in the past, and to enjoin the IRS from asking for more
Rules for written tax advice finalized
Circular 230 final regs. make ubiquitous email disclaimer no longer necessary. The IRS issued final regulations under Circular 230, Regulations Governing Practice Before the Internal Revenue Service (31 C.F.R. Part 10), on the rules for practitioners to provide written tax advice and certain other related provisions, adopting the proposed regulations
Expanded OVDP a chance to reduce penalties
The new information-reporting requirements of the Foreign Account Tax Compliance Act (FATCA), P.L. 111-147, took effect on July 1. Among other things, FATCA requires foreign financial institutions (FFIs) to report on their accounts held by U.S. taxpayers. More than 77,000 FFIs signed on and acquired approved status in the initial
New IRS appeals process starts Sept. 2
Starting Sept. 2, the IRS Office of Appeals is changing the way it handles appeals to examination decisions. Under the new Appeals Judicial Approach and Culture (AJAC) project, appeals officers are “no longer going to be examiners or investigators,” Appeals Team Manager Philip A. Oyoto told preparers at the IRS
SEC will scrutinize municipal advisers’ rules compliance
A new SEC examination initiative will scrutinize municipal advisers’ compliance with new rules and regulations that are under implementation. The SEC announced Tuesday that its Office of Compliance Inspections and Examinations (OCIE) will examine a significant percentage of municipal advisers for compliance. “The municipal adviser examination initiative will focus on
Whistleblower final rules expand definition of collected proceeds
Comprehensive final regulations issued Thursday provide rules for whistleblower awards under Secs. 7623(a) and (b), as well as rules governing the disclosure of return information under Sec. 6103(h) to pursue these claims (T.D. 9687). The regulations provide the rules for submitting information to the IRS, define key terms, provide rules
New streamlined procedures and changes to the Offshore Voluntary Disclosure Program are announced
Just in time for the Foreign Account Tax Compliance Act (FATCA), which goes into effect July 1, the IRS announced changes to its streamlined filing compliance procedures and its Offshore Voluntary Disclosure Program (OVDP) designed to make it easier for taxpayers to comply with their obligations to report offshore assets and
IRS adopts “Taxpayer Bill of Rights”
The IRS on Tuesday released a “Taxpayer Bill of Rights” intended to better communicate to taxpayers their existing statutory and administrative protections. Modeled after the U.S. Constitution’s Bill of Rights and a document of the Organisation for Economic Co-operation and Development, the 10 broad provisions were announced at a news
What tax preparers need to know about digital currency
Not long ago, few people had heard of bitcoins or digital currency. Now, digital currency routinely makes the headlines. Retailers such as Overstock.com, some sellers on online marketplace Etsy.com, and many other businesses now accept bitcoins as payment. By December 2013, it had been estimated that more than 1 million
IRS must reconsider OIC
The Tax Court holds that the IRS must fully consider an offer in compromise to promote effective tax administration. The Tax Court held that the IRS failed to adequately consider on public policy or equity grounds an offer in compromise (OIC) that a married couple had made, and it remanded
Practitioners suspended or disbarred from practice before the IRS can prepare tax returns
The IRS has decided that, as a result of the recent decision preventing it from regulating unenrolled tax return preparers, disbarment or suspension from practice before the IRS cannot include a ban on tax return preparation or blocking an individual’s preparer tax identification number (PTIN). Therefore, the Service announced that
Tax owed on full sale price where taxpayer won’t provide cost basis information
The Eleventh Circuit Court of Appeals upheld a deficiency notice of more than $5 million against a taxpayer who reported adjusted gross income of $22,921 and taxable income of $13,221 on his late-filed 2006 return (Hoang, No. 13-14398 (11th Cir. 5/2/14), aff’g T.C. Memo. 2013-127). Diep Hoang’s 2006 tax return
IRS announces two-year FATCA enforcement transition period
Foreign financial institutions that make a good-faith effort to comply with the requirements of the Foreign Account Tax Compliance Act (FATCA) will benefit from lighter enforcement during 2014 and 2015, the IRS announced on Friday (Notice 2014-33). The IRS is treating those years as a “transition period” for the implementation
New rules for innocent spouse equitable relief
A new, more comprehensive revenue procedure may spell equitable relief for many more taxpayers.
Final FATCA rules are issued
The IRS released regulations needed to implement the Foreign Account Tax Compliance Act (FATCA). FATCA, enacted as part of the Hiring Incentives to Restore Employment Act of 2010, P.L. 111-147, requires U.S. withholding agents to withhold tax on certain payments to foreign financial institutions (FFIs) that do not agree to
Tenth Circuit throws out IRS summonses
In a decision that creates a split from five other circuit courts, the Tenth Circuit Court of Appeals quashed IRS summonses that were issued after the 23-day period required under Sec. 7609(a)(1) (Jewell, Nos. 13-6069, 13-7038 (10th Cir. 4/28/14)). When the IRS issued four summonses to banks seeking records about nursing
Taxpayers must reveal tax shelter opinion letters despite attorney-client privilege
By attempting to establish good-faith and state-of-mind defenses, taxpayers put their legal knowledge and understanding into contention, and therefore they waived attorney-client privilege, the Tax Court held on Wednesday (Ad Investment 2000 Fund LLC, 142 T.C. No. 13 (2014)). As a result, the court will order the taxpayers to produce
Features
FROM THIS MONTH'S ISSUE
Tax season quick guide
Get ready for tax season with the JofA’s annual filing season quick guide, an easy-to-use compilation of dollar thresholds, tax tables, standard amounts, credits, and deductions. Download and print for quick reference this tax season.
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