SUMMARY: IRS provides additional relief for reporting of foreign bank accounts.

TOPIC: Tax Return Preparation

SECTION: 6011. General requirement of return, statement, or list

CITATION: Notice 2009-62, I.R.B. 2009-35, August 7, 2009

DATE: 2009-08-06

DOC TYPE: Notice

EXPLANATION:

SUMMARY: Uncorroborated testimony falls short of showing timely mailing of return.

TOPIC: Practice and Procedure

SECTION: 6511. Limitations on credit or refund

CITATION: Doyle-Avrigian, Plaintiff v. U.S., 2009-2 U.S.T.C. 50,577, (Ct. Cl. 2009)

DATE: 2009-08-05

DOC TYPE: Cases

EXPLANATION:

SUMMARY: District court finds interim CEO is responsible person for trust fund penalty.

TOPIC: Trust Fund Penalty

SECTION: 6672. Failure to collect and pay over tax, or attempt to evade or defeat tax

CITATION: Doulgeris v. United States, 2009-2 U.S.T.C. 50,544, (DC MD Fl. 2009)

DATE: 2009-08-02

DOC TYPE: Cases

EXPLANATION:

SUMMARY: Ninth circuit remands unlawful disclosure case; suit must be filed within two years of discovery.

TOPIC: Practice and Procedure

SECTION: 7431. Civil damages for unauthorized inspection or disclosure of returns and return information

CITATION: Aloe Vera of America, Inc. v. U.S., 2009-2 U.S.T.C. 50,530 (9th Cir. 2009)

DATE: 2009-07-29

DOC TYPE: Cases

EXPLANATION:

SUMMARY: Federal circuit rules overstatement of basis does not trigger extended six-year limitations period.

TOPIC: Statute of Limitations

SECTION: 6229. Period of limitations for making assessments

CITATION: Salman Ranch Ltd. v. United States 2009-2 U.S.T.C. 50,528, (5th Cir. 2009)

DATE: 2009-07-29

DOC TYPE: Cases

EXPLANATION:

SUMMARY: Statute of limitations bars offsetting deficiency against subsidiary; parent`s refund denied.

TOPIC: Statute of Limitations

SECTION: 6511. Limitations on credit or refund

CITATION: Abbott Laboratories v. United States, 2009-2 U.S.T.C. 50,525, (Fed. Cir. 2009)

DATE: 2009-07-28

DOC TYPE: Cases

EXPLANATION:

SUMMARY: Court accepts taxpayer`s attempt to cure installment agreement default after no response from irs.

TOPIC: Collection

SECTION: 6159. Agreements for payment of tax liability in installments

CITATION: U.S. v. Margolis., 2009-2 U.S.T.C. 50,533, (DC D.NJ., 2009)

DATE: 2009-07-27

DOC TYPE: Cases

EXPLANATION:

SUMMARY: Updated proposed regs expand scope of taxpayer advocate`s authority to issue taxpayer assistance orders.

TOPIC: Practice and Procedure

SECTION: 7811. Taxpayer Assistance Orders

CITATION: Proposed Regulations (REG-152166-05),NPRM REG-152166-05 (Jul. 27, 2009)

DATE: 2009-07-26

DOC TYPE: Proposed regulation

EXPLANATION: