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Three recent Federal Court cases, Premier Tech v. United States, No. 2:20-cv-890-TS-CMR (D. Utah 2021); Intermountain Electronics v. United States, No. 2:20-cv-00501-JNP (D. Utah 2021); and Harper v. United States, 847 F. Appx. 408 (9th Cir. 2021), remind taxpayers of the “specificity” requirements in making Claims for Refund. While we will not delve into each

Jeopardy assessments for tax collection are rare, but they are a tool available to the IRS in extraordinary circumstances. Jeopardy assessments stand outside the normal IRS assessment procedures. In general,
and in extraordinary circumstances, jeopardy assessments permit the IRS to assess additional income taxes first and only later give the taxpayer a chance to contest

IRS Appeals Conferences may now include additional participants. After the conclusion of an IRS Appeals pilot program, the results suggest that IRS Appeals benefits from including examination teams and Chief Counsel attorneys to engage with taxpayers and their representatives at the IRS Appeals conferences. They believe it improves IRS Appeals’ ability to work large, complex

As a result of the IRS campaign against cryptocurrency tax noncompliance, it has received more than 1,000 amended tax returns, collected $13 million in taxes from crypto holders with more than $20,000 of transactions, and collected another $12 million from other crypto notices. Moreover, the Treasury Department has recently released the “American Families Plan Tax

The IRS is now using data analytics and article intelligence to access billions of crypto transactions in the digital world and make the process more efficient for IRS Criminal Investigators. Once your cryptocurrency becomes fiat currency and once it goes into an exchange, the IRS is able to trace it. And the IRS is quickly

One often overlooked taxpayer right is his or her right to their full administrative case file prior to an IRS Appeals hearing. This is a legal requirement and is codified in IRC § 7803(e)(7). However, the taxpayer must affirmatively request the file. And while the Appeals Officer may try and limit access to the information