Prose by Tax Pros

  Tax disputes with the IRS can last a very long time, even under normal circumstances. The duration of these battles increased because of the Coronavirus. These holdups cause taxpayers ongoing anxiety and uncertainty. They also hurt taxpayers financially, as interest charged by the IRS continues to accumulate while the fighting ensues. Taxpayers aware of this economic reality often seek potential solutions, among them making a “deposit” with the IRS to halt interest. The rules associated with doing so are complex, of course, and they prevent some taxpayers from achieving their goals. This article analyzes key issues related to making “deposits” with the IRS, using a recent Tax Court case, Ahmed v. Commissioner, as a point of reference. Read the full article here. About Hale E. Sheppard HALE E. SHEPPARD, Esq. (B.S., M.A., J.D., LL.M., LL.M.T.) is a Shareholder in the Tax Controversy Section of Chamberlain Hrdlicka and Chair of the International Tax Group.

When engaged in a tax dispute with a partnership, the IRS wants to gather as much data as possible from all sources, including the partners. A major impediment for the IRS is that its ability to contact partners directly (during an audit, an administrative appeal, or in preparation for Tax Court litigation) can be limited or prohibited altogether. This has not stopped the IRS from trying, though. This article explains the relevant procedural matters, provides an overview of the easement donation process and its key characters, and describes four major problems that the IRS faces in approaching individual partners, using recent court orders to illustrate the situation. Read the full article here. About Hale E. Sheppard HALE E. SHEPPARD, Esq. (B.S., M.A., J.D., LL.M., LL.M.T.) is a Shareholder in the Tax Controversy Section of Chamberlain Hrdlicka and Chair of the International Tax Group.