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Tax Abatement Internal Revenue Service Tax Liability

Freeman Law

IRS Lacks Statutory Authority to Assess Certain Form 5471 Penalties

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The recent Tax Court decision in Farhy demonstrates that clever and novel arguments can carry the day in complex tax litigation matters.  In that case, the taxpayer stipulated that he:  (1) had Form 5471 filing obligations...more

Gray Reed

Asking the IRS to Abate Penalties

Gray Reed on

All kinds of penalties are being assessed by the Internal Revenue Service (IRS) against taxpayers, and more can be expected in the future.  In 1954 there were 13 penalties in the Internal Revenue Code, and now there are more...more

Gray Reed

Negotiating with the IRS Collection Division

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Once the IRS makes an assessment against a taxpayer, the taxpayer will receive several notices before the IRS takes enforced collection action....more

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