Tax Court determined extended statute-of-limitation period applied to taxpayers’ returns because the preparer had prepared returns falsely or fraudulently to evade tax.
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TOPICS
IRS Practice & Procedure
IRS Fails to Notify Victims and Social Security Administration of Identity Theft Cases
A report from the TIGTA found that the IRS had not notified victims or the Social Security Administration of many cases it detected of employment-related identity theft.
New Procedures for Amending Returns to Claim PATH Act Depreciation Changes
To help taxpayers take advantage of retroactive changes enacted late last year affecting Sec. 179 property and bonus depreciation, the IRS issued rules for filing returns to take advantage of these deductions.
Due-Diligence Hazards for Tax Practitioners: The List Keeps Growing
The director of the IRS’ Office of Professional Responsibility and veteran practitioners recently gave advice on how to steer clear of the dangers.
New User Fees Proposed for IRS Installment Agreements
The IRS is proposing to charge a variety of fees, based on whether the taxpayer uses the online application process and/or pays by direct debit.
Limitation Period Not Suspended Where Taxpayer Claims He Filed Hearing Request Late
The Tax Court rejected a taxpayer’s claim that, because he requested a collection due process hearing late, the 10-year collection period had expired.
IRS Issues Guidance on PATH Act ITIN Renewals
Individuals whose individual taxpayer identification numbers (ITINs) will expire this year under new Code provisions may renew them starting in October.
Second Circuit Holds Taxpayer Not Subject to IRS Summons
The court held that the taxpayer was protected by the Fifth Amendment privilege against self-incrimination.
IRS Changes Roth IRA Allocation Rules
The IRS eliminated the requirement that each disbursement from a designated Roth account that is directly rolled over to an eligible retirement plan be treated as a separate distribution from any amount paid directly to the employee.
Lease Payments Are Not Always Rent
This item addresses the tax consequences for the lessor and lessee in three areas.
Understatement of Income Not Fraudulent
A pattern of fraudulent conduct in a tax accountant’s preparation of his clients’ returns was not sufficient to prove that underpayments on his own returns were due to fraud.
Defeasance and Its Impact on Real Estate Transactions
While a properly structured defeasance transaction can generate a significant deduction, taxpayers should consider the totality of the transaction when assessing the after-tax impact.
IRS Service Levels Leave AICPA Members Dissatisfied
Long wait times to reach an IRS representative
on the phone shortened somewhat this filing season, compared with 2015, but the quality of the IRS’s responses is lacking.
Sec. 467 Leases and Proper Structuring for Deferral Purposes
Planning and documentation in a lease agreement are key to income deferral, but be aware that the IRS’s interpretation of Sec. 467 is stricter than once thought.
Form 1023-EZ Application Fee Will Be Lowered
The IRS is cutting the application fee small organizations must pay when applying for tax-exempt status.
Basket Contracts as Listed Transactions and Transactions of Interest
New notices provide greater detail on the types
of transactions intended to be covered
under basket contract rules.
Get Transcript Online Service Reopens
The IRS reinstated its Get Transcript Online service, which had been breached by cybercriminals last year.
House Republicans Offer ‘A Better Way’ for Taxes
This article summarizes and critiques the latest significant proposal for reform.
IRS No Longer Requires Additional Sec. 83(b) Statement With Tax Return
The IRS finalized proposed regulations issued last year intended to make it easier for taxpayers to file their returns electronically by no longer requiring taxpayers making a Sec. 83(b) election to include a copy of the election statement with their tax return.
Taxpayer Advocate Raises Concerns About IRS Use of Private Debt Collectors
Nina Olson, the national taxpayer advocate, raised several concerns about the IRS’s use of private debt collection services in her annual report to Congress, saying the practice will hurt taxpayers and harm tax administration.
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.
