Forbes1y
Tax Court Holds That It Has Jurisdiction Over Case Due To IRS Error
For income tax cases, the filing deadline is computed based on the date the IRS issues a notice of deficiency (i.e., a letter from the IRS to the taxpayer that informs the taxpayer of the agency ...
Case: Petitioner Failed to File Within 90 Days After Unclaimed Notice was Mailed; Dismissed for Lack of Jurisdiction (T.C.) (IRC §6213)
The IRS properly mailed a notice of deficiency to Petitioner’s last known address based on its most recently filed tax return, held the U.S. Tax Court, dismissing the case for ...
JD Supra2y
Tax Court in Brief | Decrescenzo v. Comm’r | Challenge to Notice of Deficiency and Penalties for Frivolous Arguments
The IRS determined various differing deficiencies ... The enclosed statement shows how we figured the deficiency.” The notice letter and enclosures consisted of 70 pages that unambiguously ...
Forbes1y
Missing Tax Court Deadline By A New York Minute
At that point the IRS will issue a notice of deficiency (NOD). The NOD is called a ninety day letter. If you want somebody entirely outside the IRS to consider the dispute i.e. the United States ...
JournalofAccountancy15d
Frivolous-tax-return penalty sustained
The IRS notified Varela by letter that his purported 2017 return “claimed ... Subsequently, the IRS issued a notice of deficiency for Varela’s 2017 tax year in the amount of $8,633. Varela petitioned ...