Guides

Issues

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.

Guides

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.

Guides

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.