Since 2020, I have repeatedly recommended a legislative change under which Congress would make foreign information return penalties and assessable penalties subject to deficiency procedures for the benefit of both the IRS and taxpayers. This change would provide taxpayers with a more efficient, less costly, and more equitable regime governing the initial imposition of these penalties, as well as the mechanisms by which they can be challenged by taxpayers.
As the National Taxpayer Advocate, I am the voice of *all* taxpayers within the IRS. As such, my office assists many different types of taxpayers in resolving tax problems with the IRS. While we typically focus on individual tax issues, our purview also includes business taxpayers. One such class of taxpayers involves marijuana-related businesses. I want to shed some light on the frustrations encountered by a growing segment of the business taxpayer population – the growers, distributors, and retailers of marijuana-related products – and educate them on federal tax law.
The CP05 notice is mailed to taxpayers to notify them that the IRS is holding their refund until the accuracy of the tax credits, income tax withholding or business expenses has been verified.
Taxpayer receives a notice or letter from the IRS and either chooses to respond to the notice or letter by paying their tax balance in full and/or filing missing tax returns; or pursuing a payment option; or the taxpayer chooses not to respond.
“[Our] Low Income Taxpayer Clinic is profoundly grateful to our [local TAS office]…for their invaluable collaboration and partnership. In 2024, TAS assisted on [14 percent] of our cases, ensuring that low-income…taxpayers receive the justice and relief they deserve. Your dedication and expertise have been instrumental in resolving so many of the most complex and challenging tax controversy cases we encounter. Your commitment to fairness and your ability to navigate the intricacies of the IRS [have] made a huge impact in the lives of our clients and our community.
• Lien Enforcement • Government Files Suit in Court • Reduce Assessment to Judgement • Foreclosure of Tax Lien • Action to Enforce Levy
The CP05 notice is mailed to taxpayers to notify them that the IRS is holding their refund until the accuracy of the tax credits, income tax withholding or business expenses has been verified.
The IRS Independent Office of Appeals (Appeals) serves as the administrative forum for any taxpayer contesting an IRS compliance action. If the IRS’s position is adverse to the taxpayer, Appeals is authorized to partially or fully concede the issue(s) in the taxpayer’s case based on the hazards of litigation.
Taxpayers who are winding down full-time work may think that they can also wind down their tax return filing requirements. However, taxpayers are never too old to have a filing requirement.
Taxpayer advocates from coast to coast, including Puerto Rico, held a combined two hundred and thirty-five events just before the start of the tax filing season.
One component of the National Taxpayer Advocate’s annual reports to Congress that doesn’t receive as much attention as it should is the research studies we conduct and present. It’s hard to overstate their value. As the IRS seeks to transform the taxpayer experience and fix problems, well-designed research that scopes problems and explores solutions is essential.