Accordingly, the notice of offset was a collection-related notice and should have included the information required by IRSRRA
The 80% electronic filing goal included in the IRSRRA
Returning to Greenbaum's observations over TBR1 and TBR2, IRSRRA is not the result of a mutual IRS/Government initiative.
This portion of the IRSRRA arose out of complaints of IRS treatment presented during Senate hearings under the leadership of Senator Roth, hearings that have been described as biased and unrepresentative of IRS typical standards of practice by former IRS Commissioner Margaret Milner Richardson.
In 1998, Congress granted a limited tax practitioner/client privilege in the IRSRRA
(section 7525) that basically extended the attorney/client privilege to confidential communications between taxpayers and federally authorized tax practitioners.
Equitable relief, created by the IRSRRA
, is available not only for proposed and assessed deficiencies, but also for liabilities that were properly reported on the joint tax return but never paid.
Pursuant to IRSRRA
, an individual taxpayer whose tax liability (without regard to interest and penalties) is less than $10,000 can require the IRS to enter into an installment agreement for a period not to exceed three years provided that within the preceding five taxable years the taxpayer and spouse have-
In addition to the impact felt from the diversion of collection resources to other work, the collection workload itself was dramatically affected by the IRSRRA
When Congress passed the IRSRRA
'98, however, the right to appeal a rejected OIC became law.
'98 required the IRS to expand its previously existing program of granting simplified installment agreements for small cases.
'98, Section 6010(m), clarified the allocation of basis to such properties.
Law: Prior to the IRSRRA
'98, the Tax Court generally had jurisdiction only in cases in which there was a tax deficiency, not a refund.