tax attorneys

What Is Substantial Authority?

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What Is Substantial Authority? Under IRS rules, the tax treatment of an item has “substantial authority” only if the weight of published cases, rules and other legal and administrative authorities is substantial in relation to the weight of opposing authorities. What percentage is substantial authority? Sec. 1. 6694-2(b)(1) before amendment by T.D. 9436), a position

What Does The Tax Court Do?

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What Does The Tax Court Do? Congress created the Tax Court as an independent judicial authority for taxpayers disputing certain IRS determinations. The Tax Court’s authority to resolve these disputes is called its jurisdiction. Generally, a taxpayer may file a petition in the Tax Court in response to certain IRS determinations. What is the role