Pre-Trial Conferences in Tax Litigation
Although pre-trial conferences are not a typical occurrence in tax litigation, the Tax Court will occasionally allow them to take place to address intractable disputes between the parties.
Although pre-trial conferences are not a typical occurrence in tax litigation, the Tax Court will occasionally allow them to take place to address intractable disputes between the parties.
A tax deficiency is a statutorily defined concept that is essential to planning and proceeding with tax litigation. Specifically, a deficiency is defined as the amount by which the correct tax exceeds the excess of:
The Tax Court is the most typical forum for the resolution of tax litigation controversies. The Tax Court is an Article I court with limited jurisdiction as expressly conferred by Congress.
When contemplating filing a petition for redetermination, the taxpayer must be sure to comply with certain procedural and jurisdictional requirements. If the taxpayer fails to do so, there is a risk that the deficiency litigation will be invalid.
When you receive a statutory notice of deficiency from the IRS, you can file for a deficiency tax litigation or a refund tax litigation proceeding.
There are two principal types of tax litigation process that can be used to determine a tax liability: deficiency litigation and refund litigation.
Cases in Tax Court can sometimes be settled through a binding arbitration process or other alternative dispute resolution methods rather than tax court litigation.
In a previous article titled Can You be Prosecuted for Perjury or False Statem
One of the most common evidence-gathering tactics used by the Criminal Investigative Division is the issuance of summonses.
An important part of surviving a Criminal Investigation process is understanding and reasonable expectations on the part of the taxpayer.