2024-05-27 Misleading Silences Are Sometimes Fine in Tax
This week we look at:
- Yet another PLR requested for missed QSST election after S shares moved to trust following death of a shareholder
- Tax preparer’s conviction for willfully filing false returns upheld on appeal despite his argument he had doing what he did for years
- Letters to taxpayer from IRS Appeals did not extend the time to file suit for a claim for refund
- A partnership had properly elected to use BBA audit provisions early, rendering IRS FPAA invalid