By Hale Sheppard Life grants few chances at true redemption. The Internal Revenue Code, likewise, is not known for facilitating taxpayer salvation. Sure, under certain circumstances, taxpayers have an opportunity to file late tax-related elections to rectify an oversight, and other forms of clemency exist. However, the general rule is that taxpayers are stuck with [...]
Archive for the ‘Administrative’ category
The Parameters of Qualified Amended Returns Examined by Tax Court in Case of First Impression
March 9, 2012Can Foreign Governments Obtain Taxpayer Information From State and Local Revenue Agencies?
February 28, 2012By Jonathan Prokup During a course that I taught about tax treaties at last week’s TEI Houston Tax School, one audience member asked whether the exchange-of-information provisions of U.S. tax treaties apply not only to the federal government but also to state and local governments. I had to confess that I did not know the [...]
Who’s Afraid of the APA?: The Application Of Administrative Law To Tax Regulations
February 15, 2012By David Shakow The Supreme Court’s decision in Mayo Foundation for Medical Education and Research v. United States means that tax practitioners must be more sensitive to administrative law and judicial deference to administrative rules. This includes gaining some familiarity with the Administrative Procedure Act (APA) and the major cases that deal with judicial deference [...]
Better Late than Never: IRS Radically Changes Aggregation Election Procedures in Passive Activity Cases
February 14, 2012By Hale Sheppard The tax code is best known for its strict rules, but it also features hundreds of taxpayer-favorable elections. The first step to evaluating and possibly taking advantage of these elections is being aware of their existence. Unfortunately, taxpayers and/or their advisors sometimes overlook an election or fail to follow the related procedures. [...]
Always Say Never: Does Financial Distress Create Reasonable Cause Sufficient To Abate Tax Penalties?
February 6, 2012By Hale Sheppard Nearly all taxpayers will face penalties by the IRS at some point, regardless of their sophistication level and size. Accordingly, tax practitioners, even those who claim not to get involved in traditional “collection” activities, must understand key aspects of abatement and collection procedures in order to effectively advise their clients. This is [...]
Silence Is Golden: Can Treasury Offer Guidance About The Tax Consequences Of A Euro Breakup?
January 23, 2012By Jonathan Prokup In this morning’s Tax Notes (subscription required), Jeremiah Coder addresses a topic that we at the Tax Blawg have discussed a couple of times over the past two years: the tax consequences of a potential breakup of the euro. For our prior coverage, see here and here. As the currency lurches towards [...]
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Phil Karter
Jonathan Prokup
David Shakow
George Connelly, Jr.
Buck Buchanan
David Bernard
Dustin Covello
Heather Pesikoff
Hale Sheppard
dustincovello
