Texas Tax Talk

Texas Tax Talk

Category Archives: Tax Court

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Expansion of IRS Innocent Spouse Relief

Posted in Tax Court, Tax Planning, Tax Practice
On September 13th the IRS issued a new revenue procedure that significantly changes equitable innocent spouse relief.  I wrote an article that was published Tuesday in the Texas Bar Association’s Texas Tax Lawyer . I have excerpted part of the article which discusses the significant changes. Change #1: Greater deference is given to the presence of… Continue Reading

How to Shift the Burden of Proof to the IRS

Posted in Tax Court
A common misperception for clients is that in Tax Court the IRS has the burden of proof to demonstrate that the changes they propose are correct.  Not so.   Unlike in the criminal arena where the Government has to prove “beyond a reasonable doubt” every element of a charged offense – in tax proceedings in the… Continue Reading