Jim Beddow, CPA

Nina Olson, IRS Taxpayer Advocate, is required to report to Congress annually and one of the things she has to report is the 10 most litigated tax issues. Here’s this years list:

1. Collection Due Process hearings (§§ 6320, 6330)
2. Summons enforcement (§§ 7602(a), 7604(a), 7609(a))
3. Trade or business expenses (§ 162(a) and related Code sections)- This covers Sole Proprietors’ Schedule C, one of the most audited forms.
4. Gross income (§ 61 and related Code sections)
5. Accuracy-related penalty (§ 6662)
6. Frivolous Issues Penalty (§ 6673 and related appellate-level sanctions)- There are still people saying the income tax is illegal and they don’t have to pay it, that it’s voluntary, that they live in Texas and so aren’t subject to it, etc.  If you hear that from someone, run.
7. Civil Actions to Enforce Federal Tax Liens or to Subject Property to Payment of Tax (§ 7403)
8. Failure to file penalty (§ 6651(a)(1)) and estimated tax penalty (§ 6654)
9. Family status issues (§§ 2, 24, 32, and 151)
10. Relief from joint and several liability for spouses (§ 6015). This includes the innocent spouse issue. The IRS won’t give in to that without a fight.

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