IRS Appeal Archives - Page 3 of 9 - John R. Dundon II, Enrolled Agent

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IRS Appeal

01 Oct IRS Restrictions on Contacting Taxpayers

Posted at 00:00h in Appeals & Audit Resolution, Audit Reconsideration, Audit Technique Guide, IRS Appeal, IRS Audit, IRS Collections, IRS Criminal Enforcement, IRS Enforcement, IRS Examination, IRS Mediation, Tax Abuse, Tax Guidance & Preparation, Tax Relief, Taxpayer Advocate, TIGTA

I've worked with many good people inside the IRS on a wide variety of cases. So please do not get me wrong I'm not bashing ALL IRS employees. However like any big bloated bureaucracy I've also worked with some real shit heads inside the IRS...

31 Jul IRS Stakeholder Liaison Meeting Summary

Posted at 00:00h in IRS Appeal, IRS Audit, IRS Centralized Insolvency, IRS Collections, IRS Criminal Enforcement, IRS Enforcement, IRS Examination, Tax Fraud, Tax Guidance & Preparation, Tax Preparer, Tax Problems & Requests, Taxpayer Advocate

The following are the notes from the most recent IRS Stakeholder Liaison Meeting held in Denver Colorado as prepared by IRS Senior Stakeholder Liaison Deborah Rodgers Michael Shuler, Local Taxpayer Advocate Nina Olson, the National Taxpayer Advocate’s (NTA) objectives report was released in June, revealed some issues...

Business Entity Selection and the Tax Consequences of Converting

18 Jul Ex Parte Communication and IRS Appeals – Rev. Proc. 2012-18

Posted at 00:00h in Appeals & Audit Resolution, IRS Appeal

Ex parte communication is oral or written communication that takes place between any IRS Appeals employees such as Appeals Officers, Settlement Officers, Appeals Team Case Leaders, Appeals Tax Computation Specialists and employees of other IRS functions without the taxpayer's representative being given an opportunity to participate in the...

19 May IRS Master File Codes 6209-8A

Posted at 00:00h in IRS Appeal, IRS Audit, IRS Centralized Insolvency, IRS Collections, IRS Criminal Enforcement, IRS Enforcement, IRS Examination, IRS Levy, IRS Lien, IRS Master File, IRS Mediation, IRS Penalties, IRS Penalty and Interest Abatement, IRS Transcript, Tax Guidance & Preparation

The first thing that I always do when investigating a tax dispute is pull the transcripts from the IRS for review. They can be really hard to read if you don't understand the Transaction Codes referenced. Transaction Codes are defined in IRS Document 6209 - Section...

10 May Understanding IRS Notices and Letters

Posted at 00:00h in IRS Appeal, IRS Audit, IRS Centralized Insolvency, IRS Collections, IRS Criminal Enforcement, IRS Enforcement, IRS Examination, IRS Levy, IRS Lien, IRS Mediation, IRS Notice, IRS Penalties, IRS Penalty and Interest Abatement, Tax Guidance & Preparation

Look on the IRS notice or letter you received in the upper right hand corner for an alpha numeric sequence. The corresponding IRS explanations below to their Notices and letters are sub categorized as follows: 1. Redesigned Notices 2. Other Notices 3. Individual Filer 4. Business Filer Redesigned Notices Notice Number Description Topic CP01H You...

02 May Updated Rules Issued for IRS Communications with Appeals Office – Rev. Proc. 2012-18

Posted at 00:00h in Appeals & Audit Resolution, IRS Appeal

The IRS Office of Appeals resolves more than 100,000 tax cases each year. Employees staffed in this function are trained to resolve disputes taking into consideration the hazards of litigation as well as the benefits of efficient tax administration. They are not necessarily trained to advocate on...

12 Mar IRS And the Trust Fund Recovery Penalty (TFRP) for Employment Tax Delinquencies

Posted at 00:00h in Employment Tax, IRS Appeal, IRS Audit, IRS Collections, IRS Enforcement, IRS Examination, IRS Penalty and Interest Abatement, Tax Guidance & Preparation, Trust Fund Recovery Penalty

Here are 5 things I learned through experience regarding TFRP: 1. An IRS Revenue Officer makes a determination to "assess" or "not assess" the Trust Fund Recovery Penalty (TFRP). Bankruptcy does not stop the Assessment Statute even though it can stop the Collection effort. One of...

17 Jan IRS Stakeholder Liaison Meeting Summary – Denver January 2012

Posted at 00:00h in Business Expense, Colorado Department of Revenue, Intent To Levy, Intent To Lien, International Tax, IRA, IRS Appeal, IRS Audit, IRS Centralized Insolvency, IRS Collections, IRS Enforcement, IRS Examination, IRS Levy, IRS Lien, IRS Mediation, IRS Penalties, IRS Penalty and Interest Abatement, IRS Transcript, Marijuana, Medical Expenses, Offshore account, PTIN, Retirement

Attached is the summary of the IRS Stakeholder Liaison Meeting I attended on January 4th 2012 in Denver, Colorado as produced by Deborah Rodgers of the IRS. Some interesting insights were revisited. The most provocative discussion surrounded the comments made by Matthew Houtsma of District...

17 Nov Reconstruction of Tax Records

Posted at 00:00h in IRS Appeal, IRS Audit, IRS Enforcement, IRS Examination, IRS Mediation, IRS Penalties, Tax Abuse, Tax Credit, Tax Deductible Expenses, Tax Fraud, Tax Guidance & Preparation, Tax Problems & Requests, United States Treasury

Treasury Regulation 1.274-5 allows for a deduction without complete documentation if you can show that you have 'substantially complied' with adequate adequate record keeping requirements. This statute is code for ...

10 Oct Dwelling Unit vs. Primary Residence

Posted at 00:00h in Appeals & Audit Resolution, IRS Appeal, IRS Audit, IRS Enforcement, IRS Examination, Rental Real Estate, Tax Guidance & Preparation, Tax Problems & Requests, Uncertain Tax Position

Many taxpayers have both a dwelling unit and a principal place of residence. Understanding the difference between the two is important for a wide variety of reasons. The file that landed on my desk today involves such a matter. The taxpayer has a dwelling unit...