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Rivkin Radler LLP

IRS Cannot Offset Taxpayer’s Refund With A Disputed Tax Liability

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Imagine the IRS notifies Taxpayer that they have an outstanding tax liability with respect to Tax Year, and that the agency intends to levy on Taxpayer’s property to collect the allegedly unpaid tax. Taxpayer challenges the...more

Freeman Law

Tax Court in Brief | Schwartz v. Comm’r | Collection Due Process; Credit Election Overpayment; Quintessential Tax Procedure

Freeman Law on

Schwartz v. Comm’r, T.C. Memo. 2022-125| December 21, 2022 | Vasquez, J. | Dkt. No. 17291-14L - Short Summary:  Eric Schwartz (“Schwartz”) and his spouse divorced.  Pursuant to those divorce proceedings, the state court...more

Freeman Law

Tax Court in Brief | Lipka v. Comm’r | Collection Alternatives, Economic Hardship, and Abuse of Discretion

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....more

Freeman Law

Tax Court in Brief | Addis v. Commissioner | Collection Due Process and Frivolous Positions

Freeman Law on

Tax Litigation:  The Week of March 28, 2022, through April 1, 2022 Porter v. Comm’r, T.C. Memo. 2022-25 | March 28, 2022 |Greaves, J. | Dkt. No. 3544-21 Golditch v. Comm’r, T.C. Memo. 2022-26 | March 29, 2022 |Lauber, J. |...more

Freeman Law

Tax Court in Brief | Bunton v. Comm’r | Collection Due Process and “Last Known Address

Freeman Law on

Tax Litigation: The Week of March 7, 2022, through March 11, 2022 Hacker v. Comm’r, T.C. Memo. 2022-16 | March 8, 2022 | Paris, J. | Dkt. No. 3870-12 Cosio v. Comm’r, T.C. Memo. 2022-18 | March 9, 2022 | Weiler, J. | Dkt....more

Freeman Law

Tax Court in Brief | Cosio v. Commissioner | Collection Due Process and Abuse of Discretion

Freeman Law on

Tax Litigation: The Week of March 7, 2022, through March 11, 2022 Hacker v. Comm’r, T.C. Memo. 2022-16 | March 8, 2022 | Paris, J. | Dkt. No. 3870-12 Rau v. Comm’r, T.C. Opin. 2022-4 | March 7, 2022 | Guy, J. | Dkt. No....more

Freeman Law

The Tax Court in Brief - December 2021 #4

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Ahmed v. Comm’r, T.C. Memo. 2021-142 |December 28, 2021 | Thornton, J. | Dkt. No. 12876-18L - Short Summary. The IRS filed a notice of federal tax lien against Mr. Ahmed with respect to his 2013, 2014, 2015, and 2016...more

Venable LLP

Should Your Lawyer Be a Grammar Nerd?

Venable LLP on

Sometimes, yes. At least that’s one takeaway from the argument in a recent U.S. Supreme Court case, Boechler, P.C. v. Commissioner of Internal Revenue. ...more

BakerHostetler

Who Says You Can't Get Into Federal Court? A Primer on the Tax Injunction Act

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Since 1937, the Tax Injunction Act (28 USC 1341) has significantly limited taxpayers' access to federal courts to hear state tax matters. In this week's episode, Matt Hunsaker provides an overview of the Act and avenues still...more

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