IRS

The ever changing scope of 230 - Part 1

In the past few years, there have been several challenges to the scope of Circular 230, and consequently, the Internal Revenue Service’s ability to regulate those that practice before it. As a consequence, what was a fairly sweeping scope of authority, has been whittled away a little at a time to now a pretty limited focus.

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"Credits are a matter of legislative grace"

The title of this post is a phrase that appears a lot in court cases and quoted often by administrative agencies. It almost always precedes a negative result for the taxpayer in question and conveniently ignored when a positive outcome is required.

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The Infamous IRS Notice - Part VII

Future After having focused on past events and activities, a look to the future is in order. The activities leading up to the Notice 2008-83 are well known and documented. Some of the reasoning behind the issuance of the Notice are known, but it is unlikely all of the reasoning will ever be fully known.

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The Infamous IRS Notice - Part VI

Court Support While the question of the Service’s authority and ability to issue Notices that change the interpretation of the Statute, taxpayers have the ability to rely on this Notice during the time period between its release and Congress’s response.

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