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The Impact of the Last Known Address Rule on United States Taxpayers

March 10, 2020

The Internal Revenue Service sends various documents and required correspondence to a taxpayer’s “last known address” as required by the Internal Revenue Code.  The meaning of the phrase “last known address” is significant, because the legal validity of a notice or document sent by the Internal Revenue Service to the taxpayer, hinges on whether it was sent to a taxpayer’s last known address.  Therefore, a taxpayer should take the appropriate measures to ensure that their current mailing address is the address the Internal Revenue Service has on file.

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The United States Tax Court Paves Way for Taxpayers to Escape Civil Penalties on Federal Income Tax Assessments

February 20, 2020

When the Internal Revenue Service conducts a tax audit, the Internal Revenue Service often looks to impose an additional tax liability upon the taxpayer.  Additionally, in more cases than not, the Internal Revenue Service also imposes civil penalties based on the asserted tax deficiency.  Explained differently, when the Internal Revenue Service proposes income tax adjustments as part of an audit, the Service also generally imposes a penalty in addition to the tax liability.  Most of the time, the civil penalty is an accuracy-related penalty under Internal Revenue Code Section 6662, which penalizes a taxpayer for his or her negligence for filing an inaccurate return.

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