When the IRS Assesses Tax Based on a Wrong Form 1099
June 29, 2026
A surprisingly common tax problem arises when a Form 1099 is issued under the wrong taxpayer identification number or in the wrong person’s name. When that happens, the IRS may...
How the IRS Uses IRC § 6901 to Collect from Third Parties
June 25, 2026
When taxpayers move assets to other people or entities, the IRS may try to collect the underlying tax from the recipient rather than only from the original taxpayer. One of...
Why the IRS Statute of Limitations Matters
June 22, 2026
In tax disputes, timing can be just as important as the underlying facts. The Internal Revenue Code contains different statutes of limitations that restrict how long the IRS has to...
Reasonable Cause: A Key Defense to IRS Penalties
June 18, 2026
Many IRS penalties are not automatic in the sense that they cannot be challenged. In the right circumstances, a taxpayer may be able to obtain relief by showing “reasonable cause.”...
What Kwong and Abdo May Mean for Taxpayers
June 15, 2026
Recent cases called Kwong and Abdo have created an important new opportunity for some taxpayers who were assessed penalties or interest, or who may have missed filing or payment deadlines...
IRS “Currently Not Collectible” Status: Relief, Risks, and Alternatives
June 12, 2026
For taxpayers facing IRS collection activity, “Currently Not Collectible,” often called CNC status, can provide important short-term relief. In general, CNC status means the IRS has determined that collecting from...
The Current State of IRS Penalties for Forms 5471, 3520, and Similar International Information Returns
June 10, 2026
Over the last several years, one of the most significant disputes in international tax enforcement has been whether the Internal Revenue Service (IRS) may administratively assess and collect certain international...
IRS Enforcement on Conservation Easements: What Taxpayers Should Know Now
June 8, 2026
The IRS’s current position on conservation easements is clear: it continues to distinguish legitimate conservation donations from abusive, promoter-driven transactions, and it remains particularly focused on syndicated conservation easements and...
When Can a Taxpayer Recover Attorneys’ Fees Under IRC 7430?
June 5, 2026
Many taxpayers assume that if they beat the IRS in Appeals or in court, the government should automatically have to pay their attorneys’ fees. That is not how the system...
Using IRS Administrative Appeals to Resolve Disputes Without Litigation
June 3, 2026
Not every dispute with the IRS needs to end up in court. In many cases, the IRS Independent Office of Appeals offers taxpayers a meaningful opportunity to resolve disagreements through...
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