Federal Tax Procedures for Attorneys

Federal Tax Procedures for Attorneys

by Patrick W. Cantrell

Paperback(New Edition)

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Product Details

ISBN-13: 9781604420357
Publisher: American Bar Association
Publication date: 05/15/2009
Edition description: New Edition
Pages: 250
Product dimensions: 7.00(w) x 9.90(h) x 1.00(d)

About the Author

W. Patrick Cantrell is licensed as an attorney and as a certified public accountant. After 33 years practicing as a CPA, including seven at the Internal Revenue Service, he opened Cantrell & Cantrell, PLLC, a tax law practice in Houston, Texas.

Table of Contents

TABLE OF CONTENTSIntroduction

Chapter 1: Examination
IRS Audit Procedures
Alternative Audit Techniques
Taxpayer Interviews
Use of Administrative Summonses by Federal Agents
Audits of Partnership Entities
Audits by IRS Specialists

Chapter 2: Administrative Appeals
The IRS Appeals Office
Freedom of Information Act Requests
Closing Agreements
Collection Due Process (CDP) Hearings

Chapter 3: Civil Tax Litigation
Choice of Forum
Deficiency Procedures
Last Known Address Problems
Tax Claim and Refund Procedures
The U.S. Tax Court: Organization, Jurisdiction, and Operation
Burden of Proof
Recovery of Costs under I.R.C. § 7430

Chapter 4: Statutes of Limitations in Tax Cases
Statutes of Limitations: General Rules
Termination of Form 872-A
Mitigation of the Statute of Limitations

Chapter 5: Penalties and Interest
Federal Penalty Structure
Penalty Abatement
Interest on Underpayments and Overpayments
Underestimate Penalties
Handling Trust Fund Liability Cases

Chapter 6: Collection Enforcement
Dealing with the IRS Collection Function
Federal Tax Liens
Federal Tax Levies
Seizure of Tangible Personalty by the IRS
Transferee and Fiduciary Liability

Chapter 7: Collection: Defenses and Remedies
Applications for Taxpayer Assistance Orders
Installment Agreements (IAs)
Offers in Compromise
Tax Issues in Bankruptcy
Innocent Spouse Defenses

Chapter 8: Fraud
Federal Tax Crimes
Civil Fraud
Failure to File Tax Returns
Criminal Tax Investigation and Prosecution
Use of Informants by the IRS

Chapter 9: Ethical Considerations
Practice before the IRS
Civil Preparer Penalties
Preparer Disclosure
Government Disclosure and Other Misconduct

Appendix A: Abbreviations and Acronyms Used in Federal Tax Procedure Matters
Appendix B: IRS Forms and Notices Used in Federal Tax Procedure Matters
Appendix C: IRS Form Letters Sent to Taxpayers
Appendix D: IRS Publications on Procedural Topics
Index

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