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IRS Practice & Procedure
Implementation Guidance for Appeals Judicial Approach and Culture Project
The goal of the IRS Appeals Judicial Approach and Culture Project is to promote a quasi-judicial approach in how the Appeals office handles its cases. It is part of an effort to improve internal and external customer perceptions of a fair, impartial, and independent Appeals office.
TIGTA Report Studies Assessment and Enforcement of Sec. 6694 Paid Preparer Penalties
TIGTA studied how effective the IRS is in using the requirements and penalty regime that apply to tax preparers. The TIGTA study attempted to determine whether controls are in place to ensure that the IRS effectively enforces and applies penalties to paid preparers as required by Sec. 6694.
Isley and IRS Appeals Cannot Work It On Out
The Tax Court held that IRS Appeals could not unilaterally accept an offer in compromise proposed by Ronald Isley, vocalist and founding member of the Isley Brothers, because the OIC covered liabilities related to a case that had been referred to the Department of Justice for prosecution.
Fast-Track Settlement Program Expanded to Small Businesses
Formerly available only to large and midsize businesses and in a geographically limited pilot program for smaller entities, the IRS’s Fast Track Settlement program is now available to smaller businesses nationwide.
Late S Corp. Return Not an Income Disclosure Despite Reference in Stockholder’s Form 1040
When information disclosing income that should have been included in the taxpayer’s return is provided to the IRS after the return is filed, that information is not considered to be disclosed on the return.
Change in “Responsible Party” Must Be Reported to the IRS
The IRS in May 2013 issued final regulations requiring any person assigned an employer identification number to provide updated responsible-party information to the IRS.
Procedures for IRS Rulings, Technical Advice, Etc., Updated for 2014
The IRS issued its annual updates to the revenue procedures that govern its operations and interactions with taxpayers. These include the list of “no ruling” areas in which the IRS will not issue letter rulings.
Top Tax News Developments in 2013
The past year featured a large number of tax developments, some of which got extensive coverage in the media, and many of which got less coverage but affect almost all taxpayers and practitioners. As we get ready to welcome a new year, here’s a look back at the most important
IRS Announces Automation of Taxpayer Resources, Start of Business Filing Season
The IRS announced on its website that, beginning in 2014, it will stop providing a number of taxpayer assistance services in person or over the phone and will shift those services online.
Senate Confirms John Koskinen as IRS Commissioner
The Senate on Friday voted 59–36 to confirm the nomination of John Koskinen to be the next IRS commissioner.
2014 Filing Season to Start Jan. 31
The IRS has finally announced an official start date for the 2014 filing season: It will start accepting returns on Jan. 31. This date is 10 days later than the originally planned starting date of Jan. 21.
Final Rules Permit Agents to Withhold FUTA for Home Care Service Recipients
The IRS issued final regulations permitting an agent authorized by the IRS under Sec. 3504 to perform certain acts normally required of employers to withhold FUTA taxes owed by home care service recipients.
Numerous Provisions Expire at Year End
Practitioners should be aware that dozens of credits and other tax incentives are expiring Dec. 31 and should prepare their clients accordingly.
Supreme Court Resolves Circuit Split on 40% Gross Valuation Misstatement Penalty
The Supreme Court held that the 40% penalty for a gross valuation misstatement applied when the partnerships at issue had been determined to be shams that lacked economic substance, and, as a result, the partners’ outside basis in the partnerships was zero.
Six-Year Statute of Limitation for Substantial Omissions of Income
The IRS has indicated that an estimated amount of flowthrough S corporation K-1 income did not constitute proper disclosure and therefore the taxpayer’s return was subject to an extended six-year statute of limitation due to a substantial omission of income.
Post-Windsor FICA Refund Procedures
The IRS announced procedures employers should follow for filing refund claims for overpaid FICA and income taxes paid on employer-provided benefits for same-sex spouses that, because of the Windsor decision, are now tax free.
Heightened Emphasis on Worker Classification
Worker classification has been a major concern for many years. While it is clear that government agencies recognize that worker misclassification is a significant problem, how to classify workers remains unclear.
IRS Abused Discretion by Not Considering Taxpayer’s Offer-in-Compromise
The Tax Court held that the IRS had abused its discretion by closing a taxpayer’s case one day after a deadline passed for him to furnish certain documents related to his proposed offer-in-compromise.
TIGTA Report Says IRS Should Do a Better Job Protecting Taxpayer Data
The IRS does not do a good job of correcting security weaknesses, thereby failing to protect taxpayer data, TIGTA concluded in a report released Thursday.
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.
