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.
Format Shift
Episode 158: Child Tax Credit Discussion
Episode 157: Advance Child Tax Credit Free Tax Prep Days
Episode 156: Effectively Representing, 8th Edition
Episode 155: Updates From the IRS
Episode154: 2848 Withdrawals and FOIAs
Episode 153: Other Work for LITC Practitioners
Episode 152: Transitions - a Talk with Andrew Belter
Episode 151: Transfer to Legal Aid of Western Missouri
Episode 150: Interview With Nina Olson
Episode 149: ABA Virtual 2021 May Tax Meeting
Episode 148: Tax Court Trial
Episode 147: IRS Chief Counsel
Episode 146: Succession Plans
Episode 145: Sharing Divorce Tax Issues
Episode 144: The American Rescue Plan
Episode 143: The LITC Grant
Episode 142: The Changing Tax Season
Episode 141: The Child Tax Credit, Continued
Episode 140: Recent Tax Recap
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