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 99: Interview With Rebecca Stavish
Episode 98: Tax March - Interview With Maura Quint
Episode 97: Interview With Andrew Belter
Episode 96: Interview With Andrew Aleman
Episode 95: Interview With Shanthy Bala
Episode 94: Further Coronavirus Tax News
Episode 93: Liens, Levies & Collection Due Process
Episode 92: Familes First Coronavirus Response Act
Episode 91.5: Further Coronavirus Tax Updates
Episode 91: Coronavirus Tax Updates
Episode 90: Family-Related Tax Issues (2 of 2)
Episode 89: Midterms and Coronavirus Tax News
Episode 88: Family-Related Tax Matters (1 of 2)
Episode 87: Installment Agreements and Settlement Offers
Episode 86: CNC and Local Standards
Episode 85: The Taxpayer Advocate Service and Systemic Advocacy
Episode 84: Tax Research
Episode 83: Interviewing Clients
Episode 82: Transcripts
Episode 81: ABA Adopt a Base Program
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