Most federal taxes are collected from taxpayers by business entities, held in a public trust for the United States and then paid over to the Internal Revenue Service (the “IRS”). While the vast majority of business entities pay over the taxes held in trust in a timely and appropriate manner,...

The Internal Revenue Code has four discreet sections that allow late filing of claims and other documents under the circumstances described in those sections. The IRS has promulgated a procedural regulation that allows it to permit late elections under prescribed circumstances. Neither the Code...

Congress has added a Taxpayer Bill of Rights (TBOR) to the Internal Revenue Code following the administrative adoption by the IRS of the identical slate of rights. The question for taxpayers and practitioners with respect to TBOR concerns its impact, if any, in seeking a remedy for certain IRS...

This article seeks to explain the role of the Tax Court both within the system of taxation and the system of tribunals of the United States. To provide this explanation, the article will address several specific areas: 1) the mission of the Court; 2) the placement of the Court within the...

This article seeks to identify and discuss the impact of Nina Olson, in her role as National Taxpayer Advocate (NTA), on low-income taxpayer clinics (LITCs). The article discusses the background of Ms. Olson including her advocacy that led to grant funding for LITCs and the background of LITCs...

The purpose of this brief is to correct and respond to two arguments in Petitioner-Appellee Altera's petition for rehearing en banc and briefs of amici supporting the petition for rehearing. First, Treasury's regulation requiring cost sharing of stock-based compensation and the Ninth Circuit...

The IRS faced a serious problem in the 1990s with taxpayers hiding their money offshore to avoid federal taxes. An International Revenue Agent, in New Jersey, Joe West, audited an individual engaged in hiding assets offshore and gained access to the offshore information through the use of a...

As of September 30, 2007, the IRS had $282 billion of unpaid assessments on its books. Of that amount $58 billion, over 20%, represents the unpaid payroll taxes due from employers. The majority of payroll taxes due from employers results from income and social security taxes collected by the...