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Update: 11th Circuit Agrees Tax Court Can’t Hear FBAR Penalty Cases
January 9th, 2026
Knowing where to file your tax challenge and which procedure to follow is essential to getting timely and effective relief when the IRS imposes incorrect assessments, penalties, or collections. A recent United States Circuit Court decision from the E…
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Categories: Tax News
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Tax Court Divided on Equitable Tolling of TEFRA Partnership Adjustments
December 2nd, 2025
Under the 1982 Tax Equity and Fiscal Responsibility Act (TEFRA), one partner in a business can face substantial fines and penalties for the poor tax choices of another partner. A recent United States Tax Court case, North Wall Holdings, LLC v IRS, as…
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Categories: Tax News
8th Circuit Blocks IRS Blocked-Income Regulation
November 10th, 2025
Complex international businesses file complicated tax returns, and the IRS often uses regulations to reallocate income among subsidiaries to reflect the company’s true income. But a recent 8th Circuit Court of Appeals decision says it can’t do th…
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Categories: Tax News
What Happens to Tax Liens After Bankruptcy and Foreclosure?
October 9th, 2025
If you have fallen behind on several of your debts, tax liens may only be one part of your financial difficulties. When unpaid debts pile up, you could end up facing tax liens, bankruptcy proceedings and foreclosures, sometimes all at once. But what…
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Categories: Tax / IRS Penalties
Sixth Circuit Says Deficiency Petition Deadline is Not Jurisdictional
September 4th, 2025
Everything in IRS tax collection comes with deadlines. This includes the 90-day tax deficiency petition deadline. But is there anything you can do if you miss that deadline and file your petition with the Tax Court late? The Sixth Circuit Court of Ap…
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Categories: Tax News
When Does the IRS Have to Withdraw Its Notice of Lien?
August 7th, 2025
If you have a substantial tax debt, you may be considering your options to avoid a federal tax lien. Offers in compromise, installment payments, and other settlement options can help you resolve your tax debt. But at what point does the IRS have to w…
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Categories: IRS Audits
Supreme Court Limits Tax Court’s Jurisdiction Over Tax Disputes
July 7th, 2025
Should the IRS have the power to strip the Tax Court of jurisdiction over a taxpayer’s case just by withdrawing its levy? The Supreme Court of the United States’s decision in Commissioner of Internal Revenue v Zuch looked at whether the Tax Court…
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Categories: Tax News
How to Contest an IRS Notice of Tax Levy
June 13th, 2025
Receiving an IRS Notice of Tax Levy can be stressful, especially when it is inaccurate or you do not have the ability to pay your unpaid taxes. When that happens, you need to know how to contest an IRS notice of levy of unpaid tax liabilities, includ…
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Categories: Tax / IRS Penalties
What Is a Tenant's Duty to Pay Rent to the IRS After a Tax Levy?
May 9th, 2025
Residential tenants often have little to no control over who they rent property from. But when a landlord runs into trouble with the IRS, it can be the tenant who is stuck paying. What is a tenant’s duty to pay rent to the IRS after a tax levy on a…
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Categories: Tax / IRS Penalties
Why You Need to Exhaust Administrative Claims in IRS Cases
April 29th, 2025
When it feels like the IRS isn’t treating you fairly, it can be tempting to immediately turn to the courts for help. However, by law, you need to exhaust administrative claims in IRS cases before you can file a complaint in federal court. The recen…
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Categories: IRS Audits
