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 81: ABA Adopt a Base Program
Episode 80: Outreach and Education
Episode 79: 2020 New Year Tax Thoughts
Episode 78: 2019 End of Year Tax Thoughts
Episode 77: LITC Grantee Conference - December 2019 Followup
Episode 76: CDP Summit Initiative - LITR Workshop Followup
Episode 75: Interview With Samantha Galvin
Episode 74: The LITC Grantee Conference - December 2019
Episode 73: Collection Due Process Summit Initiative - 2019 Low Income Taxpayer Representative Symposium
Episode 72: Tax Court Midwest Visit
Episode 71: Interview With Erin Stearns
Episode 70: Attorney Wellness
Episode 69: Interview With James Creech
Episode 68: Tax Court Settlement Day Update
Episode 67: ABA Tax Section 2019 Fall Tax Meeting Followup
Episode 66: CDP Panels at the ABA 2019 Fall Tax Meeting
Episode 65: ABA Tax Section 2019 Fall Tax Meeting
Episode 64: Nina Olson's Center for Taxpayer Rights
Episode 63: 2019 KS IRS Tax Practitioner Symposium Pt. 3 (of 3)
Episode 62: 2019 KS IRS Tax Practitioner Symposium Pt. 2 (of 3)
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