This week, Andrew Belter and William Schmidt look at some U.S. Tax Court topics.
First, the case Boechler v. Commissioner is before the U.S. Supreme Court where they have heard oral arguments. In brief, an individual was a day late and missed the statutory deadline for a Collection Due Process hearing. The Tax Court ruled that there was a strict jurisdictional deadline. At issue before the Supreme Court is whether that deadline is jurisdictional or if equitable tolling can provide any relief.
Second, there was a discussion on the ABA Section of Taxation's Pro Bono and Tax Clinics Committee listserv regarding Answers from IRS Chief Counsel in Tax Court. For years 1983-2007, the Tax Court did not require answers in S cases. We discuss the pros and cons of Answers, plus suggestions for what could replace them.
Note: the phrase we couldn't remember was financial disability. William covered that topic way back in episode 55. To learn more, you can also look at Internal Revenue Code section 6511(h), Rev. Proc. 99-21 or IRS Publication 556, page 15.
Episode 198 - Interview with Temple Law Student Randy Goldson
Episode 197 - Interview with Temple Law Student Hyo Jin Lee
Episode 196 - Interview with Mary Ann David, Senior Attorney at Legal Services of Greater Miami
Episode 195 - Interview with Shahin Rahimi, Senior Attorney at Legal Aid Society of San Diego
Episode 194 - Interview with Cal Poly Low Income Taxpayer Clinic Director and Professor Lisa Sperow
Episode 193 - Interview with Syracuse Law Professor Robert G. Nassau
Episode 192 - Giving Thanks
Episode 191 - One Year of the Inflation Reduction Act
Episode 190 - Running the Temple Law Low Income Taxpayer Clinic!
Episode 189 - How to Challenge Worker Misclassification
Episode 188 - Review of ABA Tax Section May 2023 Meeting and Interviews with Leslie Book and Mandi Matlock
Episode 187 - Reflections on the 2023 Tax Filing Season
Episode 186 - Interview with Professor Keith Fogg
Episode 185 - Interview with Former National Taxpayer Advocate Nina Olson abd ABA Christine A. Brunswick Fellow Anna Gooch
Episode 184 - Interview with National Taxpayer Advocate Erin Collins
Farewell - IRS Office of Chief Counsel
Episode 182: The Broader Discussion of IRS Funding
Episode 181: KC Current Events and IRS Funding
Episode180: Workload Balancing
Episode 179: ABA 2022 May Tax Meeting Followup
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