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 60: Interviewed by Shanna McCormack
Episode 59: Revenue Officer Training
Episode 58.5: Interview with Shanna McCormack
Episode 58: Late Filing
Episode 57: Tax Protesters
Episode 56: Nina Olson and the Taxpayer Advocate Service
Episode 55: Financial Disability
Episode 54: The Taxpayer Advocacy Panel and Tax News
Episode 53: Security Barriers for Practitioners
Episode 52: First Year Retrospective
Episode 51: Taxpayer First Act (HR 3151)
Episode 50: Collection Due Process Panel at ABA May Meeting
Episode 49: Tax Court Settlement Days
Episode 48: Tax Court at the 2019 ABA Section of Taxation May Meeting
Episode 47: IRS Commissioner Rettig at the ABA May Tax Meeting
Episode 46: 2019 ABA Tax Section May Meeting Followup
Episode 45: 2019 ABA Tax Section May Meeting
Episode 44: Liens and Levies, Part Two - Levies
Episode 43: Liens and Levies, Part One - Liens
Episode 42: Recent IRS Events in Missouri
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