The skills and knowledge required to be a Tax Litigation Attorney are not the same as that needed to be an experienced tax planning attorney. Tax litigation lawyers must be familiar with not only tax laws, but also administrative procedures that govern the day-to-day operations of the Internal Revenue Service. The Internal Revenue Manual is a large document that outlines in detail the daily rules and procedures by which IRS employees should be managed. It is used by tax auditors, IRS revenue agents, IRS appeals officers, and IRS revenue agents.
Our tax litigation lawyers handled a matter in which our client was subject to a penalty of more than $1,000,000. Our client had no reasonable cause to not file his tax returns in time, according to the IRS revenue agent and his supervisor. The Internal Revenue Manual contains a procedure called a “first-time abatement”. Taxpayers who comply with certain guidelines can have their penalties reduced under the FTA procedures. This provision is not found in the usual places. It’s not in the Internal Revenue Code or the Treasury Regulations. This provision is also not found in tax cases decided by either the United States Tax Court or any other federal … Read More