This article looks at recent academic research of interest to tax practitioners.
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TOPICS
IRS Practice & Procedure
Final rules determine when fines and penalties are deductible
The IRS issued final regulations on when fines and penalties paid to a government are not deductible by a taxpayer, including defining when a payment counts as restitution, which may be deductible.
Issuance of tax refund after expiration of Sec. 6532 time limit
Taxpayers need to be mindful of the two-year statute after filing an appeal request for reconsideration of the denial of a refund claim.
Supervisory approval not needed for Sec. 72(t) additional tax
The Sec. 72(t) additional tax on early distributions
is not a penalty that requires written supervisory approval.
Validity of notice is based on how and where it was sent, not who received it
The notice of a right to a CDP hearing is valid if it is properly sent to the taxpayer’s last known address,
regardless of who receives it at that address.
SEP plans: A cautionary tale about IRS audits
An employer’s failure to comply with SEP rules results in very costly penalties.
GAO evaluates IRS reorganization plan
A report assesses the IRS’s progress in complying with reform mandates in the Taxpayer First Act.
IRS provides details on April 15 postponement
The IRS issued a notice providing more details and clarification of its previously announced postponement of the April 15 tax deadline for individuals. The notice extends the date for making 2020 IRA contributions; however, it does not extend the date for estimated tax payments.
Tax filing postponement doesn’t go far enough, AICPA says
The IRS has postponed individual returns’ due date to May 17, but June 15 remains a more appropriate date for many reasons, the AICPA says.
IRS postpones April 15 deadline
The IRS announced that it is postponing the April 15 deadline for individual tax returns and payments. The postponement applies only to individual taxpayers. Formal guidance is expected in the near future.
AICPA asks for guidance on S corp. and partnership PPP loan forgiveness
In a letter dated March 15, the AICPA asked for IRS guidance on how S corporations and partnerships should treat tax-exempt income from PPP loan forgiveness, especially when it occurs during a different tax period.
AICPA recommends Circular 230 changes
In response to a request for comments about planned revisions to Circular 230, Regulations Governing Practice Before the IRS, the AICPA sent a letter making recommendations to the director of the IRS’s Office of Professional Responsibility.
AICPA requests tax deadline postponements until June 15
In a letter, the AICPA asked the IRS to postpone until June 15, 2021, all 2020 federal income tax and information returns and payments (e.g., extension and estimated payments) originally due April 15, 2021.
Treasury asks for comments on planned Circular 230 update
Updating the rules governing practice before the IRS is one of the goals of the IRS Office of Professional Responsibility for the new year, its director says.
Assessment statutes of limitation and the Sec. 965 transition tax
As the IRS focuses more attention on Sec. 965, it is vital that taxpayers with Sec. 965 tax liabilities and their advisers understand the potentially applicable periods of limitation on assessment.
Tax provisions in the year-end coronavirus relief act
Pandemic relief, tax extenders, and much more were included in year-end legislation.
How the IRS will treat misdirected tax refunds
The IRS announced procedures for identifying and recovering direct deposit refunds that a taxpayer did not receive in the designated account.
AICPA seeks certainty on filing deadline and relief for 2020 tax year
The AICPA has written to Treasury and the IRS, calling for certainty about the April 15 tax filing and payment deadline and for underpayment and late-payment penalty relief during the COVID-19 pandemic.
When does the centralized partnership audit regime not apply to partnership-related items?
Proposed regulations provide that the IRS may determine that the centralized partnership audit regime does not apply to adjustments to partnership-related items under certain conditions.
Congress affirms deductibility of expenses paid by forgiven PPP loans
Congress makes expenses funded by forgiven Paycheck Protection Program loans deductible.
TAX PRACTICE MANAGEMENT
2025 tax software survey
AICPA members in tax practice assess how their return preparation software performed during tax season and offer insights into their procedures.
