Advertisement
TOPICS

IRS Nonacquiesces to Tax Court Fraud Holding

The IRS nonacquiesced to the Tax Court’s decision in Norris because the IRS believes that the Tax Court improperly used a “rigid” 11-factor test to determine the existence of fraud instead of making the determination by considering the taxpayer’s entire course of conduct.

Integrating Circular 230 into the Tax Curriculum

Circular 230 is crucial to tax education because it forms the ethical standards of tax practice. Students who plan to become tax practitioners must become well acquainted with Circular 230 along with the underlying laws and regulations governing tax practice.

Circular 230: Its Day-to-Day Impact on Tax Practices

While discussions about Circular 230 usually focus on the standards it imposes relating to tax returns and opinions, the breadth and scope of Circular 230 also regulates the day-to-day business operations of tax practitioners relating to fees, client solicitations, marketing and advertising, and the management of client files and records.

IRS Launches Worker Classification Settlement Program

The IRS unveiled a program that allows taxpayers to voluntarily reclassify independent contractors as employees and pay significantly reduced prior employment taxes, with no penalties or interest.

Streamlined Installment Agreement Program Modified

The IRS Small Business/Self-Employed Division modified the maximum unpaid balance of assessment taxpayers must meet to qualify for its streamlined installment agreement program and extended the time for payment.

Annual Update on Adequate Disclosure of Return Positions Issued

The IRS released updated guidance identifying when a taxpayer’s disclosure of an item or position in an income tax return is adequate for purposes of reducing the understatement of tax penalty and the tax return preparer penalty for understatement due to unreasonable positions.

IRS Gives Transitional Relief to Form 8937 Filers

The IRS announced that, due to its late release of the required form, it will not impose penalties on issuers of stock who report incorrect 2011 information required under Sec. 6045B, as long as they make a good-faith effort to timely comply with the requirements.

PTIN System Continues to Accept 2011 Renewals

The IRS online system to apply for a PTIN is back up and running after a two-week hiatus for maintenance. The system is continuing to accept 2011 PTIN renewals even though the renewal deadline has passed.

Final Regs. on Listed Transactions for GST Tax

The IRS issued final regulations that add transactions that reduce or eliminate the GST tax as listed transactions or transactions of interest and require the disclosure of those transactions under Sec. 6011.

2010–2011 Revisions to Circular 230

This article focuses primarily on the Circular 230 tax preparer penalties and other sanctions as well as the regulations governing practice before the IRS that were revised by T.D. 9527.