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SUMMARY: Notice 2009-05 provides guidance regarding implementation of the tax return preparer penalty under section 6694(a). It will be published in IRB 2009-3 on Jan. 21, 2009.
SUMMARY: Begining Jan 1, 2008 the IRS interest rates will be: Five (5) percent for overpayments (four (4) percent in the case of a corporation; Five (5) percent for underpayments; Seven (7) percent for large corporate underpayments; and two and one-half (2.5) percent for the portion of a corporate overpayment exceeding $10,000.
SUMMARY: The Tax Court held that it has jurisdiction to review whether or not an assessment was properly made even though that issue was not raised by the taxpayer during the course of the CDP hearing because IRC 6330(c)(1) requires that the IRS ascertain whether an assessment was properly made even if the taxpayer does not raise the issue in the course of a collection due process hearing.
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