As the IRS works through its backlog of correspondence, it has posted information about checks it hasn’t cashed yet and notices that went out with incorrect dates.
IRS Practice & Procedure
TIGTA critiques IRS’s protection of taxpayer data
The IRS continues to have challenges protecting taxpayer data, and especially ensuring that its various applications provide complete and accurate audit trails, according to the Treasury Inspector General for Tax Administration (TIGTA).
Penalty defenses and the supervisory-approval requirement
Under Sec. 6751(b)(1), many penalties cannot be assessed by the IRS before written managerial approval is obtained by the immediate supervisor of the person making the initial determination of the penalties. This article discusses which penalties Sec. 6751(b)(1) applies to, when an initial determination of a penalty occurs, whose
approval is required, and other issues regarding the written-supervisory approval requirement.
The CARES Act and opportunities to implement changes on previously filed returns
The following discussion mostly focuses on the ability of partnerships to file amended returns and
the QIP technical correction under the guidance issued in Rev. Procs. 2020-23 and 2020-25, respectively.
When deductions are permitted for restitution payments
The IRS issued regulations explaining the allowance of deductions for certain fines and penalties under Sec. 162(f) as amended by the law known as the Tax Cuts and Jobs Act.
Professional responsibilities in the virtual age
As the COVID-19 pandemic forces firms to accelerate the adoption and overall use of virtual
communication tools, practitioners need to be aware that the foundational principles of ethics and best practices still apply when using these
technologies.
Overpayment due to minimum tax credit is attributable to NOL carryback
Refund claim for overpayment caused by credit is
attributable to net operating loss for purposes of the Sec. 6511(d)(2) limitation period.
An update on like-kind exchanges
Recently issued proposed regs. are generally good news for property owners with plans to make Sec. 1031 exchanges.
IRS updates annual Dirty Dozen tax schemes for 2020
The IRS issued its top 12 “Dirty Dozen” tax scams, warning people to be vigilant to avoid these schemes all year round. New to the list is the “offer in compromise mills.”
IRS reinstates PTIN user fees
The IRS said it would once again begin charging fees to issue preparer tax identification numbers (PTINs) to tax return preparers for 2021. The fee was reduced in response to court cases that challenged the IRS’s authority to charge a fee.
AICPA committee updates its conflict-of-interest advice
The Tax Practice Responsibilities Committee’s updated Guidelines on dealing with conflicts of
interest depend on rules found in the AICPA’s Code of Professional Conduct and Treasury Circular 230.
FDII and GILTI regulations finalized
The IRS issued final regs. on the foreign-derived intangible income deduction and the global intangible low-taxed income provisions enacted by the TCJA.
PTIN fees proposed to be lower when reinstated
The IRS has proposed to lower the fee it charges for preparer tax identification numbers (PTINs) when PTIN fees are reinstated.
Does substantial authority provide penalty protection?
This item discusses whether substantial authority
protects against a penalty for a return position that is contrary to a regulation.
Understanding the filing relief for ‘time-sensitive acts’ in Notice 2020-23
Carefully review Notice 2020-23 for the full scope of filing relief granted by the IRS in response to hardships caused by the coronavirus pandemic.
IRS will not postpone July 15 deadline
The IRS announced that it will not further postpone federal tax filing and payment deadlines beyond July 15.
IRS provides temporary relief from audit and collection activities
The People First Initiative provides taxpayers relief on a variety of issues ranging from easing payment guidelines to postponing compliance actions.
AICPA recommends changes to e-signature requirements
In a letter to the IRS, the AICPA asked the IRS to permanently amend its electronic signature procedures to make it easier for taxpayers and practitioners to e-file all types of returns.
Understanding the filing relief for ‘time-sensitive acts’ in Notice 2020-23
Practitioners must carefully review Notice 2020-23 to understand the full scope of filing relief granted by the IRS in response to hardships caused by the coronavirus pandemic.
Taxpayer’s failure to report foreign accounts was willful
Willful FBAR penalties upheld because taxpayer exhibited willful blindness of or recklessly violated
the FBAR reporting requirements.
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.
