News & Analysis as of

Internal Revenue Service Administrative Appeals

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Morgan Lewis

Reflections During the Recess: A Few Key Aspects of the Taxpayer First Act

Morgan Lewis on

With Congress now on August recess, it is a good time to highlight an important piece of tax legislation already enacted during the 116th United States Congress. On July 1, the Taxpayer First Act (the Act)—which attempts to...more

Mitchell, Williams, Selig, Gates & Woodyard,...

The Taxpayer First Act Changes IRS Powers in Ways Important to Your Civil and Criminal Tax Clients

On July 1, 2019, President Trump signed the Taxpayer First Act (“Act”), which includes a host of important expanded taxpayer protections ranging from adjustments to criminal tax seizures, to John Doe summonses, to the...more

Williams Mullen

President Signs Into Law the Taxpayer First Act Reforming the IRS

Williams Mullen on

On July 1, 2019, President Trump signed the Taxpayer First Act, H.R. 3151, into law.  The Act makes organizational changes to the Internal Revenue Service (the “IRS”) and implements reforms aimed at improving customer...more

White & Case LLP

Taxpayer First Act and the Independent Office of Appeals

White & Case LLP on

The Taxpayer First Act of 2019 ("TFA")1 has passed both chambers of Congress and will likely soon be signed into law by the President. The bill has a wide range of provisions affecting and modernizing the Internal Revenue...more

Dickinson Wright

Resolution of an IRS Dispute

Dickinson Wright on

Most disputes with the IRS are resolved through the administrative appeals process. The IRS Appeals Office is a separate and independent division of the IRS, and is the only level of appeal provided to taxpayers within the...more

Snell & Wilmer

You Received a Health Insurance Marketplace Notice from HHS – Now What?

Snell & Wilmer on

Take a deep breath. The HHS Health Insurance Marketplace Notice (the “Notice”) may seem to be a nuisance, but it does not necessarily mean that you will be subject to employer shared responsibility penalties....more

Nexsen Pruet, PLLC

Appeals Procedures for Tax Court Cases

Nexsen Pruet, PLLC on

The Internal Revenue Service (Service) on March 23, 2016, issued Revenue Procedure 2016-22 which clarifies and describes the practices for the administrative appeals process in cases docketed in the United States Tax Court...more

McDermott Will & Emery

Focus on Tax Controversy - December 2015

McDermott Will & Emery on

IRS Updates Administrative Appeals Process for Cases Docketed in Tax Court - In Notice 2015-72, the Internal Revenue Service (IRS) provided a proposed revenue procedure to update Rev. Proc. 87-24, 1987-1 C.B. 720, which...more

Proskauer Rose LLP

The ERISA Litigation Newsletter - September 2015

Proskauer Rose LLP on

Editor's Overview - It has been a little more than one year since the U.S. Supreme Court altered the legal landscape for litigating ERISA breach of fiduciary duty claims relating to the investment in employer stock...more

BakerHostetler

Court of Appeals Rules 23-Day Notice Requirement for Third Party Summonses is Mandatory in Tenth Circuit

BakerHostetler on

In Jewell v. U.S., Taxpayer Sam Jewell was the subject of an IRS investigation which resulted in third party summonses being issued to banks located in both the Eastern and Western Districts of Oklahoma. Mr. Jewell challenged...more

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