United States Tax Court
There are times when tax controversies cannot be resolved with the Internal Revenue Service or with a state tax authority. The professionals at Andreozzi Bluestein possess extensive experience in litigating tax matters in federal, state, and territorial courts.
United States Tax Court
There are times when tax controversies cannot be resolved with the Internal Revenue Service or with a state tax authority. The professionals at Andreozzi Bluestein possess extensive experience in litigating tax matters in federal, state, and territorial courts.
Most federal tax issues are litigated in the United States Tax Court. This federal court may address tax disputes before the IRS assesses the tax liability. A taxpayer may commence an action in the Tax Court upon receipt of a Notice of Deficiency from the IRS. The petition must be filed within 90 days (150 days if the taxpayer is not a resident of the U.S.) of the IRS mailing date on the Notice of Deficiency. The Tax Court also has jurisdiction over cases involving collection actions (liens and levies) and IRS denials of taxpayer requests for innocent spouse relief, offers in compromise, penalty abatements or other collection alternatives.
Tax Court judges have expertise in federal tax laws and are therefore uniquely qualified to interpret tax laws and regulations to ensure that taxpayers are taxed fairly by the IRS. Trials are conducted before one judge and without a jury. Decisions of the Tax Court can be appealed to the United States Court of Appeals so long as the case is not designated by the taxpayer to be a small Tax Court case.
Latest News
Can We Discern Tax Opportunities From the Haze of the Crypto Horizon?
By: Randall P. Andreozzi, Esq. While we anxiously await Treasury Department guidance on cryptocurrency (See, TIGTA Report of September 24, 2020, “The Internal Revenue Service Can Improve Taxpayer Compliance for Virtual Currency ...
Read moreIRS Flaunts Recent Tax Court Victory in Microcaptive Arena
By: Heather L. Marello, Esq. In a recent press release, IRS is again urging participants in abusive microcaptive insurance arrangements to cease participation in such transactions. This message comes after the Service’s ...
Read moreThe Tax Court Reminds Foreign Corporations of the Disastrous Consequences of Failing to File Forms 1120-F U.S. Income Tax Returns
By: Heather L. Marello, Esq. I.R.C. § 6012(a)(2) imposes an income tax return filing requirement on “every corporation subject to taxation under subtitle A.” The Treasury Regulations clarify that a foreign corporation is ...
Read moreFinally Some Good News! — Congress Locks In Full PPP Deductibility
By: Randall P. Andreozzi Congress last night passed COVID-relief legislation that included a much-anticipated provision that allows businesses to deduct qualifying expenses paid with forgiven Paycheck Protection Program (PPP) ...
Read moreHigh Income Non-Filers Beware – Audits Are Coming
By: Heather L. Marello and Kevin M. Murphy During a recent web conference, IRS Large Business and International Division Commissioner Douglas O’Donnell warned that IRS is gearing up to initiate hundreds of non-filer audits ...
Read moreIRS Captive Insurance Global Settlement Offer- Know your options.
By: Randall P. Andreozzi, Esq. In 2016 the IRS issued Notice 2016-66, which identifies certain micro captive insurance transactions as potentially abusive. The Notice generally describes the abusive arrangement as one where ...
Read moreClient Privilege – When you have it & when you don’t may surprise you.
By: Gary P. Bluestein Many accountants incorrectly assume that their communications with their tax clients are always privileged and confidential. Unfortunately, sometimes tax cases can cross over into potential criminal exposure ...
Read moreThe Lifecycle of a Tax Controversy (Part 1)
By: Michael J. Tedesco, Esq. We find that accountants and taxpayers are often unfamiliar with certain aspects of the typical tax controversy (i.e. how a tax matter moves through assessment, Tax Court/Appeals and Collections). We ...
Read moreAre 2018 State and Local Real Property Taxes Paid in 2017 deductible or not? The Answer’s in the Statute.
By: John L. Marien On December 22, 2017, President Trump signed into law the Tax Cuts and Jobs Act. In light of the various tax cuts contained in the revisions to the Internal Revenue Code, Congress was compelled to formulate ...
Read moreRecent Tax Court Ruling Limits Statute of Limitations for Foreign Account Reporting
By: Tiffany D. Bell, Esq. In 2010, Congress added to the anxiety of tax practitioners when it expanded the statute of limitations for the IRS to assess income taxes to six years when a taxpayer fails to include Form 8938 with his ...
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Whether you need tax counsel for litigation, representation before the IRS, an advocate in tax controversies, or thorough tax analysis and objective consulting, our attorneys have the experience and obtain lasting solutions.