The AICPA, in a letter to the IRS, urged the Service to expand the relief under Notice 2022-36 to include several other Code sections and forms and to extend the deadline for requesting relief to Dec. 31, 2022.
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IRS Practice & Procedure
No relief for trust fund recovery penalty
A TFRP liability is not eligible for Sec. 6015 innocent-spouse relief because it is not a liability related to a joint return.
Offer in compromise not deemed accepted
An offer in compromise submitted during a Collection Due Process proceeding is not deemed accepted under Sec. 7122(f) if it is returned to the taxpayer within 24 months of submission.
Microcaptive insurance arrangements after CIC Services
A federal district court recently held that Notice 2016-66, which classifies certain microcaptive insurance arrangements as transactions of interest that are reportable transactions under Regs. Sec. 1.6011-4, is invalid under the Administrative Procedure Act. This article discusses the ramifications of the decision for taxpayers engaging in microcaptive insurance transactions and possible responses to the decision by the IRS.
IRS service issues highlighted in national taxpayer advocate report
The annual midyear report for fiscal 2023 reviewed the IRS’s performance in the 2022 tax filing season and outlined 14 “systemic advocacy objectives” going forward.
AICPA disputes ‘misleading’ claims on new IRS funding, calls for service improvements
Despite “confusion and misinformation” about the Inflation Reduction Act’s allocations, concerns continue about the funding levels for taxpayer service, the AICPA’s president and CEO said.
IRS relieves penalties for 2019 and 2020
As part of COVID-19 pandemic relief, the IRS will automatically abate failure-to-file penalties for certain tax and information returns and refund those penalties already paid.
National taxpayer advocate appeals IRS response on scanning tech
National Taxpayer Advocate Erin Collins escalated her push for the IRS to adopt barcode scanning of paper tax returns, but the IRS would commit only to a goal of scanning certain 2022 returns.
Meaning of ‘filed’ defined for purposes of delinquent partnership returns
Delinquent partnership returns are ‘filed’ when they are delivered by the requested method to and received by an IRS official authorized to receive such returns;
IRS may enforce lien to pay off deceased life partner’s tax debts
Property of a taxpayer may be used to satisfy the tax liabilities of a life partner.
Cryptoasset clarity needed for private fund managers
This item outlines the risks private fund managers should consider when investing their portfolio in cryptoassets.
Some balance-due notices on joint returns issued in error, IRS says
Payments made by the second-listed spouse on a joint return for 2021 under certain conditions may not have been properly credited by the IRS.
IRS seeks transformation in new 5-year plan
The IRS’s fiscal 2022–26 Strategic Plan sets out goals to modernize its operations and interactions with taxpayers while adapting to new challenges and threats.
Pandemic-paused IRS return preparer visits could resume by video
The U.S. GOA recommended that the IRS pilot videoconferencing for its program singling out “high-risk” return preparers for direct compliance checks and education with respect to refundable tax credits and other taxpayer tax benefits.
AICPA recommends additional IRS backlog measures
Looking ahead to next filing season, the AICPA renews previous calls for taxpayer relief and administrative remedies to help the IRS clear overages in its return and correspondence inventories.
TIGTA: Delayed screening of IRS new hires risked taxpayer data
Temporary waiving of fingerprinting and identification procedures for new federal employees due to the pandemic could have allowed access to taxpayer data by individuals who were ineligible for federal employment.
Estates can now request late portability election relief for 5 years
The IRS extended to five years the period under which a taxpayer can use a simplified method (in lieu of a letter ruling request) to obtain an extension of time to make a portability election.
Proposed regs. would define Sec. 1256 foreign currency contracts
The IRS’s definition would exclude foreign currency options or other derivatives, but such instruments may still be subject to the Sec. 1256 mark-to-market rules under other provisions.
Passport revocation as a collection tool
Taxpayers can lose their US passports over unpaid tax debts meeting certain criteria, and courts have only limited jurisdiction to review a certification or remedy it.
IRS litigators not bound by innocent-spouse determination
The IRS Cincinnati Centralized Innocent Spouse Operation’s opinion that a taxpayer was entitled to relief was not binding on the Office of Chief Counsel as a ‘final determination’ of liability.
PRACTICE MANAGEMENT
2026 tax software survey
CPAs rate their return preparation software’s performance during this year’s tax season.
