Current Tax News Ten areas where client concerns are most often found are: Sunday, January 01, 2006 Examination: Returns are selected for audit by DIF and randomly. A tax lawyer must have a Form 2848, Power of Attorney, in order to practice before the IRS. Statute of Limitations: File Forms 872 or 872-A may extend the date. Summons: All agents of the IRS can issue summonses to ascertain tax liability, prepare a tax return, determine transferee or fiduciary liability or the correctness of any filed tax return, and to correct any tax liability. Appeals: Most tax disputes with the IRS end at the highest level of administrative appeal—the IRS Appeals Branch. When less than $10,000, a letter of protest will suffice, which includes a Preliminary Statement of the Dispute, Statement of Facts, Legal Argument, Conclusion, and Certification under oath. Numerous other filings, including Claim Form 843, Innocent Spouse Application 8857, or Lien or Levy Form 12153, will trigger Appeals jurisdiction. Collection: The IRS collects three trillion dollars in tax revenue annually. Revenue officers collect delinquent tax accounts and solicit unfiled tax returns. Authority includes seizure and selling of assets, recommending waivers of penalties, doing investigative work for Offers in Compromise, and monitoring the collection statute of limitations. Criminal: Deterrence and not tax collection is the object of the Criminal Investigation Division. Claims: When a client has overpaid a tax, the post-payment appeal process begins with the filing of either Form 843 for taxes other than income and Form 1040X for income taxes. Penalties/interest: Chief penalties include accuracy-related penalties, civil fraud, failure to file, failure to pay, fraudulent failure to file, failure to timely deposit, and trust fund recovery. Getting help from the IRS: Tax areas include revenue rulings, revenue procedures, private letter rulings, determination letters, and treasure regulations. The IRS web site at irs.gov is a source of forms and publications.   1625 K Street, NW, Suite 400 - Washington, DC 20006 PHONE: 202-824-8123  TOLL FREE: 877-839-5013