IRS Appeals

Every January, businesses race to issue Forms W-2, 1099, and 1099-NEC, but a small typo in a Social Security Number (SSN) or Taxpayer Identification Number (TIN) can turn into a

Continue Reading Back to the Future: Tax Edition — Correcting SSN/TIN Issues Before the IRS Repossesses the Delorean

Classroom participation points may boost a child’s grade in history class, but merely raising your hand won’t get you far with the IRS.  The passive activity loss rules under I.R.C.

Continue Reading No Points for Participation: Passive Activity Rules and Loss Limitations

This is the sixth in a series of ten client alerts summarizing the key provisions of the Taxpayer Assistance and Service Act (the “TAS Act”), a bipartisan legislative package introduced

Continue Reading Taxpayer Assistance and Service Act Title VI: IRS Independent Office of Appeals

After a few months of relative calm at the highest levels of the Internal Revenue Service (following turbulence and high-level executive turnover that marked much of 2025), the tax agency

Continue Reading IRS Unveils More Leadership Changes as Tax Filing Season Opens

The National Taxpayer Advocate has released her Fiscal Year 2026 Objectives Report to Congress, a statutorily-required annual report outlining the objectives of the Office of the Taxpayer Advocate for

Continue Reading Taxpayer Advocate Offers Candid Assessment of State of IRS Workforce and Other Challenges Facing the New IRS Commissioner

As part of its continuing guidance to taxpayers and practitioners about how its resumption of activities following the government shutdown is impacting pending matters, the Internal Revenue Service has published
Continue Reading IRS Publishes Frequently Asked Questions About Resumption of Appeals Cases Following Shutdown

Effective November 18, 2016, Revenue Procedure 2016-57 established the Small Business/Self-Employed (“SB/SE”) Fast Track Mediation Collection (“FTMC”) program to allow taxpayers and the IRS to resolve disputes quickly with an
Continue Reading IRS Unveils Fast Track Mediation Collection Program, Offering Expedited Resolution for Certain Collection Cases