Archive for August 2024

IRS Independent Office of Appeals  Recovering Administrative and Litigation Costs (Part I) You may be able to recover your reasonable administrative and litigation costs if you are theprevailing party and if you meet the other requirements. For example, you must exhaust youradministrative remedies within the IRS including participating in the Appeals process, and youmust not…

IRS Independent Office of Appeals  Other Options – Pass-Through Entity Appeals (BBA) The Bipartisan Budget Act of 2015 (BBA), as amended, repealed the Tax Equity and FiscalResponsibility Act of 1982 (TEFRA) partnership procedures and electing large partnershipprovisions and replaced them with an entirely new centralized partnership audit regime. BBA isgenerally effective for tax years beginning…

IRS Independent Office of Appeals  Other Options – Innocent Spouse Appeals (Part II)If you are the requesting spouse, you can petition the U.S. Tax Court to review your request forinnocent spouse relief if:

IRS Independent Office of Appeals  Other Options – Innocent Spouse Appeals (Part I) If you are the spouse who filed Form 8857, Request for Innocent Spouse Relief, requestinginnocent spouse relief (the “requesting spouse”), you can generally request an appeal if the IRSdenies your request in whole or in part. If you are a non-requesting spouse,…