2025-02-10 New Administration Pushes Foward with the CTA

This week we look at:

  • IRS issues letter ruling on IRA left to trust
  • A taxpayer mistakenly believes the IRS had conceded that his income was not subject to self-employment tax, but it hadn’t
  • The Tax Court denies a taxpayer’s deductions and claimed partnership losses due to incredibly disorganized and inadequate records
  • Taxpayer runs afoul of the “pay first, litigate later” rule when attempting to sue the IRS for a refund in US District Court in response to an assessment
  • A taxpayer’s unprocessed claim for an ERTC refund doesn’t justify CDP relief
  • The BOI - new Administration continues litigation and proposes a new due date, potential filing relief

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