News & Analysis as of

Deficiency Notices Internal Revenue Service Debt Collection

Rivkin Radler LLP

Missing the Tax Court’s 90-Day Deficiency Deadline – Now What?

Rivkin Radler LLP on

Over the years, I have observed there is only one thing that a taxpayer fears more than being notified by the IRS that their income tax return for a particular taxable year has been selected for audit, and that is being...more

McDermott Will & Emery

Tax Court Holds That Deficiency Petition 90-Day Time Limit Is Jurisdictional

McDermott Will & Emery on

Last summer, the Supreme Court of the United States held that the 30-day time limit to file a Collection Due Process (CDP) petition is a non-jurisdictional deadline subject to equitable tolling (Boechler, P.C. v....more

Burr & Forman

What Do All These IRS Collection Letters Mean?

Burr & Forman on

When someone owes the IRS taxes, as a result of not paying the tax shown as due on a tax return or where the IRS audits and imposes additional taxes owed, the IRS will “assess” this tax liability, and with penalties and...more

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