26 U.S.C. § 6213: The Tax Court Petition Period
Section 6213 establishes the general petition period following a statutory notice of deficiency and restricts assessment while that period remains open.
Tax Court & AppealsRead the analysis ↗
Kentucky Tax Lawyer Research Library
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Treas. Reg. § 301.6331-1: Federal Levy Procedure
The Treasury regulation under section 6331 explains federal levy authority and procedural rules that operate alongside the statute and IRS collection guidance.
IRS CollectionRead the analysis ↗
Treas. Reg. § 301.7122-1: Offers in Compromise
The offer-in-compromise regulation distinguishes doubt as to liability, doubt as to collectibility, and effective-tax-administration grounds.
Resolution OptionsRead the analysis ↗
IRS Guidance Is Not the Internal Revenue Code: A Research Hierarchy
IRS publications, FAQs, notices, revenue procedures, rulings, and the Internal Revenue Manual do not all carry the same authority as statutes, regulations, or judicial decisions.
Tax ResearchRead the analysis ↗
Using the Internal Revenue Manual in an IRS Collection Case
The Internal Revenue Manual describes IRS operating procedures and can help explain collection activity, but it must be used with the governing Code, regulations, and actual account record.
IRS CollectionRead the analysis ↗
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