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 140: Recent Tax Recap
Episode 139: Highlights for the Tax Season
Episode 138: Tax Court Return
Episode 137: The Child Tax Credit
Episode 136: State of IRS Collections
Episode 135: CAF Unit Issues
Episode 134: Form 1040 Basics, Part 2
Episode 133: Form 1040 Basics, Pt. 1
Episode 132: The Recovery Rebate Credit
Episode 131: 2021 New Year Tax Thoughts
Episode 130: 2021 Annual LITC Grantee Conference
Episode 129: 2020 Year in Review
Episode 128: Collections Presentation
Episode 127: 2020 LITC Conference
Episode 126: Form 2848 and the CAF Unit
Episode 125: Taxgirl Interview
Episode 124: Virtual Tax Conferences
Episode 123: November Updates
Episode 122: Virtual Tax Court
Episode 121: U.S. Tax Court Nonattorney Examination
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