Paul L. Caron
Dean
Pepperdine Caruso
School of Law
6212
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Lesson From The Tax Court: Proving Last Known Address
Many statutes require the IRS to send taxpayers notices. What confuses my students (and many taxpayers) is that the statutes rarely require that the taxpayer actually receive a particular notice; they just require the IRS to properly send the notice. And the IRS will always meet the statutory requirement if the IRS sends the notice
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Lesson From The Tax Court: What Makes A NOD Invalid?
When the IRS determines a deficiency of tax, it is then “authorized to send notice of such deficiency to the taxpayer.” §6212(a). That’s called a Notice of Deficiency (NOD). The taxpayer generally has 90 days from the date of the NOD to petition the Tax Court to ask for a “redetermination of the deficiency.” §6213(a).
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Lesson From The Tax Court: What Makes A NOD Invalid?
When the IRS determines a deficiency of tax, it is then “authorized to send notice of such deficiency to the taxpayer.” §6212(a). That’s called a Notice of Deficiency (NOD). The taxpayer generally has 90 days from the date of the NOD to petition the Tax Court to ask for a “redetermination of the deficiency.” §6213(a).
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Lesson From The Tax Court: Attend Carefully To Your Entity Baskets
Easter approaches. On that day our church grounds will be overrun with children scampering to collect eggs into the various baskets, bags, and other containers they bring (or we give them if they need). They do not have to worry about what kind of container they use to collect their eggs. The candy will taste
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Lesson From The Tax Court: Attend Carefully To Your Entity Baskets
Easter approaches. On that day our church grounds will be overrun with children scampering to collect eggs into the various baskets, bags, and other containers they bring (or we give them if they need). They do not have to worry about what kind of container they use to collect their eggs. The candy will taste
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Lesson From The Tax Court: Take The Administrative Appeal
Taxpayers famously focus on trying to get their “day in court” against the evil IRS. The Independent Office of Appeals (Appeals) is no court. It is not surprising, then, that taxpayers’ myopia often leads them down the dangerously wrong path of ignoring their opportunity to go to Appeals. Today’s lesson teaches us one reason that
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Lesson From The Tax Court: Take The Administrative Appeal
Taxpayers famously focus on trying to get their “day in court” against the evil IRS. The Independent Office of Appeals (Appeals) is no court. It is not surprising, then, that taxpayers’ myopia often leads them down the dangerously wrong path of ignoring their opportunity to go to Appeals. Today’s lesson teaches us one reason that