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Equitable tolling does not apply to excuse late filing of petition

On remand from the Eighth Circuit and after the Supreme Court held in the case that the Sec. 6330(d)(1) period for filing a Tax Court petition for a review of a Collection Due Process determination is nonjurisdictional, the Tax Court denied equitable tolling of the deadline.

Final partnership adjustment not issued timely

The Tax Court found a regulation invalid to the extent it holds the period open for the IRS to issue a final partnership adjustment longer than the statutory 270 days after a partnership has submitted “everything required” for a complete modification request.

IRS furloughs nearly half its workers, closes most operations

Under an updated contingency plan, nearly 40,000 of the approximately 74,000 IRS workers will stay on the job, including more than 24,000 in Taxpayer Services. In response to the plan, the AICPA recommended “fair, reasonable, and practical relief measures to mitigate the negative impact of the shutdown” on taxpayers and practitioners.

Transactions between related parties

Limitations on transactions between related parties include restrictions on installment sales of property and potential reallocation of tax benefits of certain personal services corporations.