Private Letter Ruling 202244002, November 4, 2022 - In a recent Private Letter Ruling, the Internal Revenue Service granted a partnership 120 days from the date of the letter to make an election under §754 of the Internal...more
The IRS sends a CP504 Notice when a taxpayer has failed to pay a balance owed. The CP504 Notice is a Notice of Intent to Levy issued pursuant to Section 6331(d) of the Internal Revenue Code. If a taxpayer fails to make...more
One of the little-known tools in the IRS collection tool belt is the ability to revoke a taxpayer’s passport where the taxpayer has a “seriously delinquent tax debt.”...more
This post focuses on the recent case of Polselli, et al. v. IRS, Case No. 21-1010 (6th Cir., January 7, 2022).
The recent Sixth Circuit’s recent opinion in Polselli, et al. v. IRS, Case No. 21-1010 (6th Cir., January 7,...more
This program is the first of Freeman Law’s multi-class course designed to prepare CPAs and Enrolled Agents for the Tax Court’s admissions examination. Participants will receive an overview of the Tax Court and will learn...more
8/19/2021
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Estate Tax ,
Federal Rules of Evidence ,
Gift Tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
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Legal Ethics ,
Subject Matter Jurisdiction ,
Tax Court ,
Tax Litigation ,
Webinars
The recent case of In re Bowman, Case No. 20-11512, Section A (Bankr. E.D. La., July 12, 2021) addresses an interesting intersection of tax and bankruptcy law. Specifically, it looks at the issue of whether bankruptcy courts...more