petition in tax court Archives - Patrick T. Sheehan & Associates, Attorneys at Law, P.C.

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Taxpayer Cannot Challenge His Tax Liability in the Tax Court

Because the taxpayer had unpaid liability due to the IRS, the IRS issued the Final Notice of Intent To Levy seeking to collect the taxpayer’s unpaid liability for 2008 and 2009. In response, the taxpayer filed a Form 12153, Request…

December 04, 2014

Frivolous Penalty Assessed and IRS Collection Continues

Are you being represented correctly? A husband and wife failed to timely file their federal Form 1040 income tax return for 2004. As a result, the IRS prepared a Substitute for Return for the husband using third party information and…

December 02, 2014