![]() ![]() If we do contact other persons, you have a right to request a list of those contacted. Our need to contact other persons may continue as long as there is activity in your case. The law prohibits us from disclosing any more information than is necessary to obtain or verify the information we are seeking. If we do contact other persons, such as a neighbor, bank, employer, or employees, we will generally need to tell them limited information, such as your name. However, we sometimes talk with other persons if we need information that you have been unable to provide, or to verify information we have received. Generally, the IRS will deal directly with you or your duly authorized representative. The government essentially argued that IRS did comply with its notice requirements, pointing to the Publication 1 that IRS had sent to the taxpayers two years before when it notified them of the NRP audit. JB and PB filed a suit in district court to quash the summons arguing that IRS failed to give them reasonable advance notice. In seeking that information, IRS did not separately notify the taxpayers about its contacting the court. In the meantime the NRP audit went forward and two years later in 2015 the IRS issued a summons to the California Supreme Court seeking “copies of billing statements, invoices, or other documents. ![]() IRS refused and the taxpayers filed suit to stop the audit. In particular they passed on declarations from a doctor that the audit would “worsen his hypertension and contribute to hypertensive retinopathy, a deteriorating eye condition, as well as his serious hearing loss.” (I am no doctor and am not sure how hearing loss connects to the audit but that is not really relevant for this opinion). The taxpayers requested to be excused from the NRP audit due to JB’s age and poor health. ![]() The letter that notified the taxpayers that they were selected for audit described the NRP audit process and asked the taxpayers to contact a revenue agent. The NRP audits are extensive line by line reviews of all items on a tax return. In 2013, they were lucky enough to be selected for a National Research Project (NRP) IRS audit for the 2011 tax year. The taxpayers JB and PB are an elderly couple JB is an attorney who as state-appointed counsel represented capital defendants in California. ![]()
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