Taxpayer Bill of Rights 2: Hearings Before the Subcommittee on Private Retirement Plans and Oversight of the Internal Revenue Service of the Committee on Finance, United States Senate, One Hundred Second Congress, First and Second Session [sic], on S. 2239, December 10, 1991 and February 21, 1992, Band 4U.S. Government Printing Office, 1992 - 275 Seiten |
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Seite 8
... burden of proof that he did not receive the additional income. from the reviewer said the following, "The information" — this is referring to that investigation — "would tie up loose ends, but not change the tax liability and would take ...
... burden of proof that he did not receive the additional income. from the reviewer said the following, "The information" — this is referring to that investigation — "would tie up loose ends, but not change the tax liability and would take ...
Seite 3
... burden of proving the 1099 was wrong . The IRS pursued this taxpayer . They pursued Mr. Portillo all the way to the 5th Circuit Court of Appeals where ultimately the court this summer determined that the Internal Revenue Service's ...
... burden of proving the 1099 was wrong . The IRS pursued this taxpayer . They pursued Mr. Portillo all the way to the 5th Circuit Court of Appeals where ultimately the court this summer determined that the Internal Revenue Service's ...
Seite 7
... burden of proving that he did not receive the income . Now I say to you , sir , you go back 4 years and try to prove that you did not receive income from somebody else that claims he paid it to you in cash , and he had no receipts and ...
... burden of proving that he did not receive the income . Now I say to you , sir , you go back 4 years and try to prove that you did not receive income from somebody else that claims he paid it to you in cash , and he had no receipts and ...
Seite 8
... burden of proof that he did not receive the additional income . Once again , the group manager in responding to the request from the reviewer said the following , " The information " -this is re- ferring to that investigation- " would ...
... burden of proof that he did not receive the additional income . Once again , the group manager in responding to the request from the reviewer said the following , " The information " -this is re- ferring to that investigation- " would ...
Seite 10
... burden of proof to the Internal Revenue Service when a taxpayer substan- tially prevails . In my view nothing creates more careful consideration by an IRS auditor or attorney as surely as the possibility that he or she may be ...
... burden of proof to the Internal Revenue Service when a taxpayer substan- tially prevails . In my view nothing creates more careful consideration by an IRS auditor or attorney as surely as the possibility that he or she may be ...
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1986 Code relating action administrative costs amended amount assessment attorney Attorney/client privilege audit believe Bill of Rights Bob Livingston burden Chairman collection Committee Congress contractor Current law David Pryor designated summons determination district enrolled agent fees filed going hardship hearing implementation income information return installment agreement Internal Revenue Service interview IRS auditor IRS employees IRS Procedure IRS's issue JOSLIN LEEPER legislation levy lien LOVELADY notice of deficiency notify NSPA Ombudsman payers payment penalty person PODOLIN Portillo prepared statement Problem Resolution Office proposed protect refund regulations request responsible Senator Grassley Senator PRYOR Senator Reid small business spouse statute of limitations Subcommittee subsection Tax Court Tax Executives Institute tax laws tax liability tax returns tax system Taxpayer Advocate Taxpayer Assistance Orders taxpayer rights Thank tion U.S. SENATOR West Memphis Whistleblowers
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Seite 192 - ... file in the office of the Commissioner the opinion of the Solicitor of Internal Revenue, or of the officer acting as such, with his reasons therefor, with a statement of the amount of tax assessed, the amount of additional tax or penalty imposed by law in consequence of the neglect or delinquency of the person against whom the tax is assessed, and the amount actually paid in accordance with the terms of the compromise.
Seite 239 - If any officer or employee of the Internal Revenue Service knowingly, or by reason of negligence, fails to release a lien under section 6325 on property of the taxpayer...
Seite 236 - States; and (ii) attorney fees shall not be awarded in excess of $75 per hour unless the court determines that an increase in the cost of living or a special factor, such as the limited availability of qualified attorneys for the proceedings involved, justifies a higher fee.); (B) "party...
Seite 236 - For the purposes of this subsection— (A) "fees and other expenses" includes the reasonable expenses of expert witnesses, the reasonable cost of any study, analysis, engineering report, test, or project which is found by the court to be necessary for the preparation of the party's case, and...
Seite 235 - The amendments made by this section shall take effect on the date of enactment of this Act...
Seite 110 - States or any creditor of the taxpayer involved) which — "(i) establishes that the position of the United States in the civil proceeding was unreasonable, and "(iiXl) has substantially prevailed with respect to the amount in controversy...
Seite 155 - Extensive hearings followed before the House Committee on Ways and Means, and the Senate Committee on Finance.
Seite 237 - States in the civil proceeding was unreasonable, and "(iiXl) has substantially prevailed with respect to the amount in controversy, or "(II) has substantially prevailed with respect to the most significant issue or set of issues presented...
Seite 230 - In the case of any individual not described in paragraph (1), the amount of the wages, salary, and other income payable to or received by him during any applicable pay period or other fiscal period (as determined under regulations prescribed by the Secretary) which is exempt from levy under subsection (a) (9) shall be an amount (determined under such regulations) which as •nearly as possible will result in...
Seite 127 - Any claim arising in respect of the assessment or collection of any tax or customs duty, or the detention of any goods or merchandise by any officer of customs or excise or any other law-enforcement officer.