Lost Your CDP Hearing? The IRC 6330 Tax Court Guide
Appeals sustained a lien or levy? You have 30 days to petition the Tax Court. How IRC 6330(d) review works, and how these cases are won and lost.
Latest
Can the IRS Raise Your Bill in Tax Court? The IRC 6214 Guide
Yes, the IRS can ask the Tax Court for more tax or new penalties after you petition, but it must plead and prove them. How IRC 6214 works and how to respond.
Theft Loss From a Scam Denied? The Section 165 Tax Court Guide
Lost money to a scam or Ponzi scheme and the IRS denied your theft loss? Which scams still qualify, the year that counts, and the IRA tax trap.
Net Operating Loss Disallowed? The Section 172 Tax Court Guide
The IRS disallowed your net operating loss carryforward. How Section 172 works now, what the Tax Court makes you prove, and how to check the IRS's math.
Raising the Statute of Limitations in Tax Court: The IRC 6501 Guide
Your notice of deficiency came over three years after you filed. How to raise the IRC 6501 defense in Tax Court, who proves what, and the IRS's exceptions.
Tax Court's $25,000 Frivolous-Position Penalty: The IRC 6673 Guide
The Tax Court can add up to $25,000 to your bill for a frivolous position or a case run for delay. What triggers IRC 6673, what does not, and how to avoid it.
Proving Your Tax Court Petition Was Filed on Time: The Mailbox Rule
How the Tax Court counts the petition deadline, which postmarks it accepts, why e-filing has no mailbox rule, and how to answer an IRS motion to dismiss.
Can Tax Court Remove Your Late-Filing Penalty? The IRC 6651 Guide
The IRS added late-filing and late-payment penalties. Which part the Tax Court can remove, who must prove what, and how reasonable cause is really won.
Innocent Spouse Relief in Tax Court: After the IRS Says No
The IRS denied your innocent spouse request? A stand-alone law gives you 90 days to take it to Tax Court. How the judge decides—and what your ex can do.
Repair or Improvement? Fighting IRS Capitalization in Tax Court
The IRS recharacterized your repairs as capital improvements. Here is how the tangible property regulations decide it—and how to fight back.
Notice CP508C: IRS Passport Certification and How To Undo It
The IRS told the State Department about your tax debt. What CP508C means, who can't be certified, how decertification works, and when Tax Court can help.
Can You Get IRS Interest Removed? The § 6404 Abatement Guide
The IRS won't remove interest for reasonable cause—but § 6404 opens narrow doors, and the Tax Court can review a denial. Here's how the process works.
Guides
Burden of Proof in Tax Court: Who Has To Prove What
The IRS's numbers are presumed correct—usually you must prove them wrong. Here are the five situations where the burden sits on the IRS instead.
Guides
The $10,000 SALT Cap Is Gone—Here's the New One
The 2025 law raised the state-and-local-tax cap to $40,000. Here's the new number, who it actually helps, and what draws an IRS notice.
Issues
Bad-Debt Deductions: How To Fight a Disallowed § 166 Loss in Tax Court
You lent money you never got back, claimed a bad-debt deduction, and the IRS disallowed it. Here's how the § 166 fight really works—and what it's worth.
Issues
The IRS Taxed You on Unemployment You Never Got? Fight a 1099-G
A state sent the IRS a Form 1099-G for unemployment you never collected—maybe from a state you've never lived in. Here's how to fight it in Tax Court.
Issues
Child and Dependent Care Credit: Defending a § 21 Disallowance
The IRS denied your child and dependent care credit. It's a different credit from the CTC, with its own rules—and most losses are fixable paperwork.
Issues
The Penalty Defense That Costs You Nothing: § 6751(b)
Before the IRS can hit you with most penalties, a supervisor must approve it in writing—and the IRS has to prove it. If it can't, the penalty falls.
Issues
IRA Deduction Denied? Why Your Plan at Work Matters
The IRS disallowed your traditional-IRA deduction. How to fight a phase-out, no-compensation, or excess-contribution ruling—and what to do if it's right.
Issues
The 75% Fraud Penalty: Who Has To Prove It
If your Notice of Deficiency asserts the civil fraud penalty, the IRS has to prove it by clear and convincing evidence. Here is what that means for you.
Issues
The IRS Filed Your Return? Why It's Too High
The IRS filed a tax return for you and the number is way too high—on purpose. Here's how filing the real return slashes the deficiency in Tax Court.
Issues
The Penalty You Can't Talk Your Way Out Of
The IRS hit you with a §6654 estimated-tax penalty and you want to fight it. The hard truth: there's no reasonable-cause defense. Here's where you really win.
Issues
Settlement Taxable? Why the IRS Says You Owe Tax
You settled a lawsuit and thought the money was tax-free—then a 1099 or Notice of Deficiency arrived. Here's when a settlement is excludable and when it isn't.
Issues
Mortgage Interest Denied? Why the IRS Cut It Back
The IRS slashed your mortgage-interest (or investment-interest) deduction. The deduction is real—but it's hedged with traps. Here's how to win it back.