Administrative Procedure Act and IRS Deficiency Notices

By way (once again) of Paul Caron (emphasis is mine): Smith: The APA’s Reasoned-Explanation Rule and IRS Deficiency Notices Patrick J. Smith (Ivins, Phillips & Barker, Washington, D.C.), The APA’s Reasoned-Explanation Rule and IRS Deficiency Notices, 134…

Read More

Tax Court Orders Now Available Online

The United States Tax Court today issued the following press release announcing changes to its website, including the online publication of the Court’s orders: PRESS RELEASE Chief Judge John O. Colvin announced today that, to assist…

Read More

Top 10 Most Challenged Tax Issues

National Taxpayer Advocate Nina Olson has issued her annual report on the most frequently litigated tax issues: Internal Revenue Code § 7803(c)(2)(B)(ii)(X) requires the National Taxpayer Advocate to identify the ten tax issues most often litigated…

Read More

Unrepresented Taxpayers Lose 90% of Tax Court Cases

Did you ever wonder why the IRS prevails in trials before the United States Tax Court in 9 out of 10 cases. The more paranoid among attribute the government’s lopsided success rate to a silent conspiracy…

Read More

Tax Court Update: An IRS Agent Fails to Corroborate her eBay Expenses

In a summary opinion issued yesterday the Tax Court held that an IRS revenue officer failed to substantiate expenses she claimed in her eBay business.¹ Below is an excerpt from the Court’s opinion in Orellana v. Commissioner,…

Read More