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IRS Appeals Conferences may now include additional participants. After the conclusion of an IRS Appeals pilot program, the results suggest that IRS Appeals benefits from including examination teams and Chief Counsel attorneys to engage with taxpayers and their representatives at the IRS Appeals conferences. They believe it improves… Read More

Normally, an Innocent Spouse Determination Letter denying relief is final unless a taxpayer files a Tax Court Petition to challenge the denial. If that Tax Court Petition deadline (90 days from the Innocent Spouse Determination Letter) is missed, then the taxpayer is forever stuck with the Innocent Spouse… Read More

As a result of the IRS campaign against cryptocurrency tax noncompliance, it has received more than 1,000 amended tax returns, collected $13 million in taxes from crypto holders with more than $20,000 of transactions, and collected another $12 million from other crypto notices. Moreover, the Treasury Department has… Read More

The IRS is now using data analytics and article intelligence to access billions of crypto transactions in the digital world and make the process more efficient for IRS Criminal Investigators. Once your cryptocurrency becomes fiat currency and once it goes into an exchange, the IRS is able to… Read More

One often overlooked taxpayer right is his or her right to their full administrative case file prior to an IRS Appeals hearing. This is a legal requirement and is codified in IRC § 7803(e)(7). However, the taxpayer must affirmatively request the file. And while the Appeals Officer may… Read More

You may submit an Offer in Compromise (OIC) as part of a Collection Due Process hearing at IRS Appeals. One big advantage in doing so is your right to challenge a denial of the OIC in Tax Court; you do not have this right if you submit an… Read More