Preparing an effective IRS protest: how to win the tax case without going to court
Article Abstract:
An accurate well-written protest to Internal Revenue Service (IRS) appeals officers can result in a favorable settlement when an agreement cannot be reached with an IRS examining agent. Written protests are required only in field examination cases where the disputed amount is over $2,500. However, it may be advisable to file a written protest, even in office examination cases, where a significant amount of money is involved. Filing an administrative appeal (a written protest or request for hearing) is usually the best course of action, as it delays or avoids payment of the tax. Procedural requirements for the filing of protests are discussed, as are the scope and preparation of the protest, statement of facts, and supporting material.
Publication Name: Taxation for Accountants
Subject: Business
ISSN: 0040-0165
Year: 1986
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Final cash transaction reporting Regs
Article Abstract:
Final Regulations covering the reporting requirements for cash in excess of $10,000 received in a business transaction have been issued by the IRS. The Regulations, which take effect on Feb 2, 1992, supersede the Proposed Regulations released in May 1991. The Regulations require that all transactions that involve over $10,000 in cash be reported on Form 8300. The Regulations also specify that monetary instruments such as bank drafts and cashier's checks that are used to avoid cash reporting requirements be reported as well, provided that they have a face value less than $10,000. The cash reporting regulations have been issued as part of the IRS's drive to combat the laundering of money derived from illegal activities.
Publication Name: Taxation for Accountants
Subject: Business
ISSN: 0040-0165
Year: 1992
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Effective preparation of protest can facilitate settlement with the IRS
Article Abstract:
The only pre-litigation opportunity provided to tax practitioners is the opportunity to prepare and submit a protest in response to a preliminary note of deficiency, also known as a '30-day letter', to question the position of the examining agent. This can be an excellent tool for the practitioner, and can serve as a solid base upon which to build an argument at a later court proceeding when a favorable settlement cannot be reached. The process of preparing this 30-day letter, the general requirements of protests, applicable laws, statements of facts, and attorney's fees are discussed.
Publication Name: Taxation for Accountants
Subject: Business
ISSN: 0040-0165
Year: 1986
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