In January 2009, Nina Olson, the National Taxpayer Advocate, presented her annual report to Congress, outlining the IRS system and legislative suggestions for improving the federal tax system.
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TOPICS
IRS Practice & Procedure
Consent to Extend the Statute of Limitation
Sec. 6501(c) allows the IRS and a taxpayer to consent in writing to extend the statute of limitation to assess tax.
Establishing Substantial Authority for Undisclosed Tax Positions
To avoid the imposition of a penalty for an understatement related to an undisclosed position, a practioner must meet the substantial authority standard with respect to the position.
IRS Announces Procedures for Tax Return Preparer Penalties
The IRS recently issued internal memoranda setting forth procedures for tax return preparer penalties in taxpayer examinations.
FBAR Penalties Reduced for Six Months
The IRS has provided a framework for voluntary disclosure requests containing offshore issues, such as previously undisclosed foreign financial accounts and entities.
New Tax Preparer Rules for Disclosure and Use of Return Information
The IRS released final regulations under Sec. 7216, providing guidance for tax return preparers about the disclosure or use of tax return information.
IRS Announces an End to Private Debt Collection Services
The IRS confirmed that it will not renew expiring contracts with private debt collection agencies, effectively ending its private debt collection program.
IRS Expands Alternative Dispute Resolution Opportunities
The IRS recently expanded access to the fast track resolution program and to Appeals mediation and arbitration procedures.
Return Preparer’s Advice Does Not Prevent Accuracy-Related Penalty
In a recent decision, the Tax Court partially upheld accuracy-related penalties against a taxpayer because it failed to reasonably rely in good faith on advice from its tax return preparer.
The National CPA-IRS Tax Issues Meeting
The AICPA IRS Practice and Procedures Committee’s annual IRS tax issues meeting was held in Washington, DC, on October 29, 2008.
Accountant Workpaper Privilege Upheld by First Circuit
The First Circuit upheld a district court’s decision that the work-product privilege applies to certain accountant workpapers.
New Information Reporting Requirements for Payment Card and Third-Party Network Transactions
A provision in the Housing and Economic Recovery Act of 2008 contains new information return reporting requirements related to the settlement of reportable transactions involving payment card (e.g., credit and debit cards) and third-party network transactions.
Decision Not to Reinstate Offer Upheld
The Tax Court held that an IRS Appeals officer’s decision in a collection due process hearing not to reinstate a taxpayer’s offer in compromise after the taxpayer failed to meet a condition of the offer in compromise was not an abuse of discretion.
New Material Adviser Reporting Rules
The IRS has issued proposed regulations relating to the reporting rules for material advisers (REG-160872-04).
IRS Provides a Simplified Method for Late Filing Relief
The IRS has provided a simplified method to request relief for certain late filings under Secs. 897 and 1445.
IRS Issues Final Regulations on Sec. 6694 Tax Return Preparer Penalties
The IRS issued final regulations implementing the changes to the Sec. 6694 tax return preparer penalties.
Withholding Taxes Made a Tier I Issue
The IRS announced that it was adding withholding taxes to its list of Tier I issues
IRS Crackdown on Form 5471: A Sign of Things to Come?
In August 2008, the IRS began sending “soft” letters to corporate taxpayers warning that beginning in 2009, the Service would automatically assert penalties on any late-filed Forms 1120 that include a Form 5471.
New Regs. Govern Overseas Disclosure and Use of Taxpayer Information
The IRS issued final regulations under Sec. 7216 to update the existing rules to address current tax industry practices, such as electronic preparation and filing, expanded tax and nontax service offerings, and resource sharing across national borders.
The Tax Return Preparer Standard: Policy Developments
The tax return preparer standard set forth in Sec. 6694 has been subject to a series of revisions and refinements.
INDIVIDUALS
Current Developments in Taxation of Individuals: Part 1
This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending October 2025.
