The Tax Court held that it could not order the IRS to reopen an individual’s whistleblower claim under Sec. 7623(b), and the court dismissed his petition.
Advertisement
TOPICS
IRS Practice & Procedure
IRS Issues Interim ITIN Procedures for 2011 Tax Returns on Extension
The IRS has posted special instructions for certifying acceptance agents to use in certifying identification documents for 2011 tax year filers who are filing on extension—returns that are due by Oct. 15, 2012.
A Trust Fund Recovery Penalty Primer
This item discusses the basic mechanics of the trust fund recovery penalty, what qualifies someone as responsible for payroll taxes, and what constitutes willfulness.
IRS Issues Blueprint for IC-DISC Audits
The IRS released its advanced audit guide for agents involved in examinations of IC-DISCs.
Statistical Sampling in Federal Tax Filings
Numerous tax agencies—state, federal, and foreign—have published guidelines for taxpayer use of sampling for estimating values that are reported or claimed on tax returns.
Watch for Further IRS Pronouncements on ITINs
The AICPA has voiced concerns to the IRS about the Service’s interim rules that foreign nationals must generally include original documentation with Form W-7, Application for IRS Individual Taxpayer Identification Number.
New LB&I Knowledge Management Strategies: IPGs and IPNs
Issue practice groups and international practice networks represent a new strategy the LB&I Division to pool and perpetuate institutional expertise.
TIGTA Shines Light on Large Tax Delinquencies of Federal Government Agencies
TIGTA found that 70 federal agencies had unpaid employment taxes totaling $14 million, and 18 federal agencies were delinquent in filing 39 employment tax returns, as of Dec. 31, 2011.
PTIN Information Release Concerns Aired
The AICPA has expressed concerns to the IRS about the IRS’s public release of information of CPAs and other federal tax return preparers the IRS collects as part of its PTIN registration requirement.
U.S. Attorneys Are Authorized to Fight Stolen Identity Refund Fraud
In an effort to better combat crimes involving stolen identities and tax refund fraud, the Justice Department is changing the procedures it uses to handle such cases.
IRS Proposes Changes to Circular 230 Rules Governing Written Tax Advice
The IRS released proposed regulations that would eliminate the complex rules in Circular 230 governing covered opinions.
AICPA Urges Congress to Quickly Fix Tax Cliff
In written and oral testimony, Jeffrey Porter, CPA, addressed the impact of tax uncertainty in several areas and made recommendations on behalf of the AICPA for alleviating some of that uncertainty.
Publicly Traded Property Defined for Determining Issue Price of Debt Instruments
The IRS issued final regulations defining “publicly traded property” to determine the issue price of a debt instrument.
Use of Wrong Delivery Service Results in Dismissal of Tax Court Petition
Taxpayers who chose the wrong type of FedEx delivery service did not get the benefit of the timely mailing/timely filing rule and as a result had their petition dismissed.
Taxpayer Advocate Service Changes Criteria for Accepting Cases
The Taxpayer Advocate Service changed its criteria for accepting individual taxpayer cases for assistance.
IRS Stops Issuing ITINs Without Original Documents
The IRS will no longer issue ITINs unless the applicants provide original documents, such as passports or birth certificates, or certified copies of those documents from the issuing agencies.
New FAQs and Rules for Offshore Voluntary Disclosure Program
The IRS released 55 questions and answers updated for the 2012 offshore voluntary disclosure program.
Tax Court Petition Suspends Limitation Period
The Eleventh Circuit held that the filing of a Tax Court petition “was a proceeding in respect of the deficiency” that suspended the running of the limitation period for the IRS to assess a tax deficiency even though the petition responded to a defective notice.
IRS Launches Redesigned Website; Temporarily Takes Down Some Services
A redesigned IRS.gov website went live on Aug. 30; however, the IRS also announced that it is taking down several of its online services during the Labor Day weekend.
IRS Changes Stance on Application of Sec. 6662 Penalty to Frozen Refundable Credits
The IRS announced that it would no longer impose a penalty under Sec. 6662 for a substantial understatement of tax when a taxpayer claims a refundable tax credit he or she is not entitled to, but the IRS does not pay the refund or approve the credit.
INDIVIDUALS
Current Developments in Taxation of Individuals: Part 1
This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending October 2025.
