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IRS nonacquiesces in collection due process case that disqualified appeals officer. E-mail

SUMMARY: IRS nonacquiesces in collection due process case that disqualified appeals officer.

TOPIC: Collection

SECTION: 6330. Notice and opportunity for hearing before levy

CITATION: AOD 2009-01 (May 11, 2009)

DATE: 2009-05-10

DOC TYPE: Actions on Decisions (AOD)

EXPLANATION:
 
Partnership converting to corporation can make immediate sub s election. E-mail

SUMMARY: Partnership converting to corporation can make immediate sub s election.

TOPIC: S-corps

SECTION: 1361. S corporation defined

CITATION: Rev. Rul. 2009-15, I.R.B. 2009-21, May 7, 2009

DATE: 2009-05-06

DOC TYPE: Revenue Ruling

EXPLANATION:
 
Tax court has jurisdiction over trust fund penalty in CDP review. E-mail

SUMMARY: Tax court has jurisdiction over trust fund penalty in CDP review.

TOPIC: Collection

SECTION: 6321. Lien for taxes

CITATION: Mason v. Commissioner., 132 T.C. No. 14, (May 6, 2009)

DATE: 2009-05-05

DOC TYPE: Cases

EXPLANATION:
 
Collateral estoppel prevents corporation from denying employment tax liability. E-mail

SUMMARY: Collateral estoppel prevents corporation from denying employment tax liability.

TOPIC: Employment Tax

SECTION: 3401. Definitions

CITATION: HI-Q Personnel, Inc. v. Commissioner.,132 T.C. No. 13, (May 4, 2009)

DATE: 2009-05-03

DOC TYPE: Cases

EXPLANATION:
 
IRS may enforce third party summons of tax advisor referred to doj. E-mail

SUMMARY: IRS may enforce third party summons of tax advisor referred to doj.

TOPIC: Summons

SECTION: 7602. Examination of books and witnesses

CITATION: S. Khan, 2009-1 U.S.T.C. 50,361, (May 1, 2009)

DATE: 2009-04-30

DOC TYPE: Cases

EXPLANATION:
 
Proposed regs issued to cover grantor retained interest trusts. E-mail

SUMMARY: Proposed regs issued to cover grantor retained interest trusts.

TOPIC: Gross Income

SECTION: 2036. Transfers with retained life estate

CITATION: Proposed Regulations, NPRM REG-119532-08 (Apr. 30, 2009)

DATE: 2009-04-29

DOC TYPE: Proposed regulation

EXPLANATION:
 
IRS extends deadline for multiemployer plans to request WRERA relief. E-mail

SUMMARY: IRS extends deadline for multiemployer plans to request WRERA relief.

TOPIC: Pension and IRA

SECTION: 0000. No specific section

CITATION: Notice 2009-42, I.R.B. 2009-20, April 30, 2009

DATE: 2009-04-29

DOC TYPE: Notice

EXPLANATION:
 
Payment of taxes before CDP hearing fails to restore OIC. E-mail

SUMMARY: Payment of taxes before CDP hearing fails to restore OIC.

TOPIC: Collection

SECTION: 6330. Notice and opportunity for hearing before levy

CITATION: M. Poindexter, 2009-1 U.S.T.C. 50,347, (10th Cir. 2009)

DATE: 2009-04-22

DOC TYPE: Cases

EXPLANATION:
 
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