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7th Annual Young Tax Lawyers Conference
March 5, 2020
Don’t miss our own Lisa Nelson and Jonathan Amitrano speaking at the 7th Annual Young Tax Lawyers (YTL) Conference held at UCI School of Law on April 17, 2020. The Law Offices of A. Lavar Taylor is proud to be a Diamond Sponsor for this event.
A. Lavar Taylor Speaking About Current Developments in Collection Enforcement
January 10, 2020
A. Lavar Taylor will be a panel speaker on the program of “Current Developments in Collection Enforcement” on Friday, January 31, 2020 at the ABA’s Midyear Tax Meeting 2020 in Boca Raton, Florida.
IRS Commissioner Charles P. Rettig Will Deliver Keynote Address at Second Annual UCI-A. Lavar Taylor Tax Symposium
December 2, 2019
The University of California, Irvine School of Law (UCI Law) is delighted to announce that the Commissioner of the Internal Revenue Service (IRS), Charles P. Rettig, will be the keynote speaker at the Second Annual UCI-A. Lavar Taylor Tax Symposium at noon on February 24, 2020 on tax and artificial Intelligence. The Commissioner will discuss IRS initiatives in this area.
Are Alleged Alter Egos, Successors in Interest and/or Transferees Entitled to Their Own Collection Due Process Rights Under Sections 6320 And 6330? Part 5
December 10, 2018
Original appeared in Procedurally Taxing
In Part 4 of this series, I discussed the questions of 1) how a putative alter ego/successor in interest/transferee of a taxpayer might pursue litigation in the Tax Court to raise the questions of whether they are entitled to Collection Due Process (“CDP”) rights under sections 6330 and 6320 of the Code, independent of the rights of the original taxpayer who incurred the liability, 2) whether the government can take administrative collection action against a putative alter ego/successor in interest/transferee without first obtaining a District Court judgment or making a separate assessment, and 3) whether the Tax Court has the ability to address issues 1 and 2 above, given that no notice of determination is ever issued by the IRS in these situations.
Are Alleged Alter Egos, Successors in Interest and/or Transferees Entitled to Their Own Collection Due Process Rights Under Sections 6320 and 6330? Part 4
December 3, 2018
Original appeared in Procedurally Taxing
This post looks at the question of how a putative alter ego, successor in interest or transferee of a taxpayer might pursue litigation in the Tax Court to raise the question of whether they are entitled to Collection Due Process (“CDP”) rights under §§6330 and 6320 of the Code, independent of the rights of the original taxpayer who incurred the liability. This discussion assumes, of course, that the IRS has the legal ability to pursue administrative collection action against a putative alter ego or successor in interest of the taxpayer, without first obtaining a judgment in District Court or without first making a separate assessment against the third party under section 6901. As is explained in Part 3 of this series, such an assumption may not be correct.
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Recent Posts
- March 30, 2020 IRS Audit Statute of Limitations May Be Extended for Failure to Report Foreign Financial Activity
- March 10, 2020 The Impact of the Last Known Address Rule on United States Taxpayers
- March 5, 2020 7th Annual Young Tax Lawyers Conference
- February 20, 2020 The United States Tax Court Paves Way for Taxpayers to Escape Civil Penalties on Federal Income Tax Assessments
- January 10, 2020 A. Lavar Taylor Speaking About Current Developments in Collection Enforcement