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.
Episode180: Workload Balancing
Episode 179: ABA 2022 May Tax Meeting Followup
Episode 178: OIC Updates and Other Tax Topics
Episode 177: Boechler Decision and ABA May Tax CDP Presentation
Episode 176: PPS Issues and Criminal Tax Referrals
Episode 175: Signing for Clients and More LITC Grant Report Talk
Episode 174: PPS and the LITC Grant Report
Episode 172: John Gilmore Interview on ID.me
Episode 171: 2022 ABA Section of Taxation Midyear Meeting
Episode 170: State and Federal Tax Issues
Episode 169: 2022 New Year Tax Resolutions
Episode 168: 2021 End of Year Wrap-Up
Working With TAS in 2021
Episode 166 - Offers in Compromise Review and Updates
Episode 165: FAQs and Other Updates
Episode 164: Should We Have Filing Statuses?
Episode 163: Tax Court Withdrawals
Episode 162: Tax Court and ABA Tax Meeting Followup
Episode 161: Tax Court and ABA Virtual Fall Tax Meeting Update
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