Notice of Deficiency: Your Ticket to U.S. Tax Court
What is a Notice of Deficiency? A Notice of Deficiency issued by the IRS serves as a taxpayer’s final notice of additional tax owed. The notice is generally issued after the IRS audits a taxpayer and proposes changes to a tax return. More importantly, a Notice of Deficiency is a legal document that allows a taxpayer to challenge the IRS in U.S. Tax Court without having to first pay the additional…
Tyler DeWitt Rated by Super Lawyers Rising Stars in Tax Practice Area
For the third year in a row, Tyler DeWitt has been rated by Super Lawyers as a Rising Star in the practice area of tax, an honor reserved for lawyers who exhibit excellence in practice. The designation signifies that he is a top-rated tax attorney as recognized by peers. Super Lawyers selects attorneys using a patented multiphase selection process. Peer nominations and evaluations are combined with independent research. Each candidate…
Suspension or Expulsion from the IRS e-File Program: What Preparers Need to Know
The IRS strictly regulates tax professionals and firms (referred to as “Providers”) and maintains wide discretion in suspending or expelling Providers from the IRS e-file program. When a Provider is suspended or expelled, any tax returns that are electronically filed under their Electronic Filing Identification Number (“EFIN”) are automatically rejected by the IRS. Over the years, I have represented Providers who suddenly and unexpectedly found themselves fighting to keep their…
IRS CP2000 Notice – What to Do and How to Respond
The Internal Revenue Service’s CP2000 notice is a computer-generated notice received by taxpayers after filing an income tax return. The purpose of a CP2000 notice is to inform a taxpayer that information the I.R.S. received from third parties (employers, banks, brokerages, etc.) does not match the information reported on the taxpayer’s return. Taxpayers often receive CP2000 notices when taxpayers’ income or payment is inaccurately reported or unreported on their tax…
When the IRS Comes Knocking: Understanding an IRS Summons
The IRS has broad authority through its summons power when conducting an audit or investigation to obtain and examine information from taxpayers and third-parties. In fact, I.R.C. § 7602 allows the IRS to issue a summons to: (1) a person liable for tax, (2) an officer or employee of such person, (3) a person with possession, custody, or care of the business books of a person liable for tax, or…