Andrew Belter and William Schmidt have a discussion on two items regarding client deadlines in taxes.
-What to do when a client shows up with a short deadline for the IRS or Tax Court? This might put an attorney in a bind regarding the work to do in a short amount of time. Entering an appearance in court is easy for an attorney to do, but requires the judge’s approval to for the attorney to withdraw from the case. In other instances, there may be a scramble to file paperwork to the IRS. What are some considerations necessary to trust the client?
-Also, there is the issue of premature assessments. The U.S. Tax Court is backed up on processing petitions they have received. In the meantime, the IRS has not received notices that those petitions were filed. Their Collections department may then believe there is no petition and incorrectly send out a notice regarding the deficiency. To address this issue, there is an email address to contact and provide your case number in the situation: taxcourt.petitioner.premature.assessment@irs.gov
Here is the recent press release from the Tax Court on premature assessments: 08162021.pdf (ustaxcourt.gov)
Episode 120: IRS Litigation
Episode 119: Appeals
Episode 118: Collections
Episode 117: IRS Examination
Episode 116: Tax Return Processing
Episode 115: Tax Preparation
Episode 114: IRS Virtual Settlement Days
Episode 113: Tax Podcasts
Episode 112: Interview With Bobby French
Episode 111: The Reliability of IRS FAQs
Episode 110: EIP Payment Issue Update
Episode 109: Tax Procedure Course Wrapup
Episode 108: Ethical Issues in Taxes
Episode 107: Persuasive Writing
Episode 106: Tax Court - A Focus on Litigation
Episode 105: Tax Court During Covid
Episode 104: Introduction to Tax Court
Episode 103: The New Normal for Taxes
Episode 102: Interview With William Chun
Episode 101: Interview With Paul Harrison
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