Private Causes of Action under Section 7431 and 7433, by Frank Agostino, Esq. and Jeffrey Dirmann, Esq.
The Taxpayer Bill of Rights codifies the general concept that taxpayers and their tax return information is entitled to strict confidentiality. The Taxpayer Bill of Rights provides that taxpayers have the right to expect that any information they provide to the IRS will not be disclosed unless authorized by the taxpayer or by law. Taxpayers have the right to expect appropriate action will be taken against employees, return preparers, and others who wrongfully use or disclose taxpayer return information.
Hardship and Disasters, by Frank Agostino, Esq. and Mary Katherine Browne, LL.M.
The Internal Revenue Code (“Code”) provides guidelines for the calculation and collection of tax. When tax professionals and the Internal Revenue Service (“IRS” or “Service”) are applying those guidelines to determine a taxpayer’s liability or the appropriate method to collect that liability if at all, two considerations are frequently ignored – disaster2 and hardship. This article will discuss several sections of the Code where hardship and disasters can affect the calculation and collection, including compromise, of tax liabilities.