26 U.S.C. § 6201: Federal Tax Assessment Authority
Section 6201 authorizes the Secretary to assess taxes, additions, amounts, and penalties imposed by the Internal Revenue Code.
Assessments & AuditsRead the analysis ↗
Kentucky Tax Lawyer Research Library
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26 U.S.C. § 6159: IRS Installment Agreements
Section 6159 authorizes written agreements permitting a tax liability to be paid in installments when that will facilitate collection.
Resolution OptionsRead the analysis ↗
26 U.S.C. § 6672: Trust Fund Recovery Penalty
Section 6672 can impose personal liability on a responsible person who willfully fails to collect, account for, or pay over trust-fund taxes.
Payroll TaxesRead the analysis ↗
Treas. Reg. § 301.6159-1: Installment-Agreement Procedure
The installment-agreement regulation addresses requests, acceptance, terms, modification, termination, appeal rights, and levy restrictions.
Resolution OptionsRead the analysis ↗
26 U.S.C. § 7122: Federal Tax Compromises
Section 7122 authorizes compromise of civil and criminal tax cases and establishes procedural requirements for offers in compromise.
Resolution OptionsRead the analysis ↗
Treas. Reg. § 301.6020-1: IRS-Prepared Returns
The regulation under section 6020 distinguishes returns prepared with taxpayer cooperation from returns executed by the IRS after nonfiling.
Unfiled ReturnsRead the analysis ↗
Treas. Reg. § 301.6212-1: Deficiency-Notice Procedure
The regulation under section 6212 addresses issuance of deficiency notices and joint-return notice rules.
Tax Court & AppealsRead the analysis ↗
U.S. Tax Court Petitions: Filing, Service, and the Administrative Record
A Tax Court petition invokes a specialized federal court's jurisdiction and must follow the statute, current court rules, and accepted filing procedures.
Tax Court & AppealsRead the analysis ↗
26 U.S.C. § 7521: Taxpayer Interviews and Representation
Section 7521 supplies safeguards for taxpayer interviews, including explanations of process, recording rules, and consultation with an authorized representative.
Taxpayer RepresentationRead the analysis ↗
26 U.S.C. § 7525: The Tax-Practitioner Privilege and Its Limits
Section 7525 extends a limited confidentiality privilege to certain tax advice from federally authorized tax practitioners, with significant exceptions.
Taxpayer RepresentationRead the analysis ↗
26 U.S.C. § 6011: Who Must File a Tax Return
Section 6011 supplies the general statutory duty to make a return or statement when required by the Code or regulations.
Unfiled ReturnsRead the analysis ↗
26 U.S.C. § 6020: Returns Prepared by the IRS
Section 6020 authorizes returns prepared with a taxpayer's cooperation and returns made by the Secretary when a required return is not filed.
Unfiled ReturnsRead the analysis ↗
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