Intended as a basic reference manual for the casual practitioner of tax procedure as well as by more serious scholars, Federal Tax Procedures for Attorneys offers a nuts-and-bolts approach to solving specific and common problems that arise in everyday tax practice. Unlike casebooks or treatises, this practical guide primarily with Internal Revenue Code sections 6000 to 9000. Author W. Patrick Cantrell, who is both a lawyer and a tax professional, provides insight and practical tips on all aspects of federal tax controversies, including: * Examination and IRS audit procedures* Administrative appeals, FOIA requests, and collection due process hearings* Statutes of limitations in tax cases* Penalties and interest* Collection enforcement, including tax liens, tax levies, and seizure of tangible property by the IRA* Defenses and remedies in collection* Fraud* Ethical considerations Practice tips are highlighted throughout the text. For ease of reference, notes and citations follow each subject within a chapter rather than being grouped at the end.
Appendices include abbreviations and acronyms used in federal tax procedure matters, IRS forms and notices, IRS form letters sent to taxpayers, and a list of IRS publications on procedural topics.
Auflage
Sprache
Verlagsort
Zielgruppe
Maße
Höhe: 251 mm
Breite: 180 mm
Dicke: 25 mm
Gewicht
ISBN-13
978-1-63425-259-1 (9781634252591)
Copyright in bibliographic data and cover images is held by Nielsen Book Services Limited or by the publishers or by their respective licensors: all rights reserved.
Schweitzer Klassifikation
W. Patrick Cantrell is licensed as an attorney and as a certified public accountant. After 33 years practicing as a CPA, including seven at the Internal Revenue Service, he opened Cantrell & Cantrell, PLLC, a tax law practice in Houston, Texas.
TABLE OF CONTENTS Introduction Chapter 1: Examination IRS Audit Procedures Alternative Audit Techniques Taxpayer Interviews Use of Administrative Summonses by Federal Agents Audits of Partnership Entities Audits by IRS Specialists Chapter 2: Administrative Appeals The IRS Appeals Office Freedom of Information Act Requests Closing Agreements Collection Due Process (CDP) Hearings Chapter 3: Civil Tax Litigation Choice of Forum Deficiency Procedures Last Known Address Problems Tax Claim and Refund Procedures The U.S. Tax Court: Organization, Jurisdiction, and Operation Burden of Proof Recovery of Costs under I.R.C. 7430 Chapter 4: Statutes of Limitations in Tax Cases Statutes of Limitations: General Rules Termination of Form 872-A Mitigation of the Statute of Limitations Chapter 5: Penalties and Interest Federal Penalty Structure Penalty Abatement Interest on Underpayments and Overpayments Underestimate Penalties Handling Trust Fund Liability Cases Chapter 6: Collection Enforcement Dealing with the IRS Collection Function Federal Tax Liens Federal Tax Levies Seizure of Tangible Personalty by the IRS Transferee and Fiduciary Liability Chapter 7: Collection: Defenses and Remedies Applications for Taxpayer Assistance Orders Installment Agreements (IAs) Offers in Compromise Tax Issues in Bankruptcy Innocent Spouse Defenses Chapter 8: Fraud Federal Tax Crimes Civil Fraud Failure to File Tax Returns Criminal Tax Investigation and Prosecution Use of Informants by the IRS Chapter 9: Ethical Considerations Practice before the IRS Civil Preparer Penalties Preparer Disclosure Government Disclosure and Other Misconduct Appendix A: Abbreviations and Acronyms Used in Federal Tax Procedure Matters Appendix B: IRS Forms and Notices Used in Federal Tax Procedure Matters Appendix C: IRS Form Letters Sent to Taxpayers Appendix D: IRS Publications on Procedural Topics Index
