Emphasizing Physical Injuries In Settlement Agreements

The United States Tax Court (Court) recently issued a decision highlighting, yet again, the importance of clear drafting in settlement agreements. In Doyle v. Comm’r of Internal Revenue, T.C. Memo. 2019-8, the Court held that the taxpayer could not exclude amounts, pursuant to Internal Revenue Code § 104(a)(2), that he received from a settlement agreement. [...]

Can The IRS Really Seize My Assets Without Telling Me First?

The Internal Revenue Service (IRS) can utilize its jeopardy levy function (i.e., taking a taxpayer’s assets) to pursue a taxpayer’s assets prior to issuing a jeopardy assessment (i.e., telling a taxpayer how much they owe). In Chief Counsel Advice (CCA) 201830013, the IRS clarified the circumstances in which it would take such drastic steps. In [...]

FOIAs and GDPAs: How Requests for Information Can Help Practitioners Resolve Cases with the IRS or DOR

This is the fourth article in the Freedom Of Information Act Requests (FOIAs) and Government Data Practices Act Requests (GDPAs) series. This series is intended to provide taxpayers and practitioners with answers to the most commonly asked questions relating to the use of FOIAs and GDPAs. The use of FOIAs and GDPAs allow taxpayers and [...]

Minnesota Tax Law Attorneys

FOIAs and GDPAs: How Requests for Information Can Help Practitioners Resolve Cases with the IRS or DOR

This is the third article in the Freedom Of Information Act Requests (FOIAs) and Government Data Practices Act Requests (GDPAs) series. This series is intended to provide taxpayers and practitioners with answers to the most commonly asked questions relating to the use of FOIAs and GDPAs. The use of FOIAs and GDPAs allow taxpayers and [...]

Minnesota Tax Law Attorneys

FOIAs and GDPAs: How Requests for Information Can Help Resolve Cases with the IRS or MDR

This is the second article in the Freedom Of Information Act Requests (FOIAs) and Government Data Practices Act Requests (GDPAs) series. This series is intended to provide taxpayers and practitioners with answers to the most commonly asked questions relating to the use of FOIAs and GDPAs. The use of FOIAs and GDPAs allow taxpayers and [...]

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