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Full-Text Articles in Law
Obtaining Relief From Federal Tax Levies, T. Fogg
Obtaining Relief From Federal Tax Levies, T. Fogg
T. Keith Fogg
A levy is an administrative means of collecting taxes by seizure or taking of the taxpayer's property to satisfy delinquent tax liabilities. A levy is analogous to, but something more than, an attachment, garnishment, or other similar creditor's remedy. This chapter explains the levy process, the power of a levy and ways for moving past the levy.
Effectively Representing Your Client Before The Irs, 6th Edition, T. Fogg
Effectively Representing Your Client Before The Irs, 6th Edition, T. Fogg
T. Keith Fogg
"Written by some of the most experienced tax controversy lawyers in the United States, this two-volume reference provides an in-depth discussion of the law and is replete with realistic examples and hundreds of practice tips to aid tax practitioners during all stages of representation before the IRS in controversy matters, including exam, appeals, Tax Court, refund actions, and collection matters. The companion DVD contains select audio and video recordings, gleaned from past ABA Section of Taxation meetings, and is supplemented with meeting materials relevant to your practice." -- ABA Web Shop
Obtaining Relief From Federal Tax Lien, T. Fogg, Frank Agostino
Obtaining Relief From Federal Tax Lien, T. Fogg, Frank Agostino
T. Keith Fogg
The Supreme Court has said that Congress could not have chosen broader language than it did when setting out the scope of the federal tax lien. This chapter discusses the scope of the lien as well as how the federal tax lien is created, the priority issues present when the federal tax lien competes with other liens, and how to remove the lien.
Utilizing Bankruptcy To Reduce Outstanding Tax Debts, T. Fogg, Kenneth Weil
Utilizing Bankruptcy To Reduce Outstanding Tax Debts, T. Fogg, Kenneth Weil
T. Keith Fogg
In general, Congress set out to strike a balance in the bankruptcy code between the need for government entities to collect taxes, the need to promote a fresh start for debtors and the desire to create a relatively balanced playing field for competing creditors. This chapter explains how tax creditors will do well when they quickly collect the debts due to them. They will do much less well if the debts have gotten old. Exceptions to this general rule exist for tax debts secured by a tax lien or debts arising from the debtor's collection of funds on behalf of …
Tax Issues Facing Clients Of Legal Services, T. Fogg
Tax Issues Facing Clients Of Legal Services, T. Fogg
T. Keith Fogg
This article seeks to highlight tax issues facing clients of legal services. It discusses several specific issues that routinely arise. The article also discusses some of the challenges facing attorneys within legal services that take on a tax clinic and offers some advice on how to address those challenges.
A Calendar Call Staffing Success Story, T. Keith Fogg
A Calendar Call Staffing Success Story, T. Keith Fogg
T. Keith Fogg
This short article appeared in 33(2) ABA Section of Taxation NewsQuarterly (Winter 2014), p. 13.
Meeting Leads To Changes To Certain Practices In The Tax Court, T. Fogg
Meeting Leads To Changes To Certain Practices In The Tax Court, T. Fogg
T. Keith Fogg
This article covers a meeting of the ABA Taxation section's Pro Bono members, Tax Court judges, the National Taxpayer Advocate, and representatives from the IRS Office of Chief Counsel. The group discussed a wide range of issues that impact pro se petitioners, who file almost 70% of the Tax Court's cases.
An Access To Justice Milestone, T. Fogg
An Access To Justice Milestone, T. Fogg
T. Keith Fogg
Short article on agreements between Low income tax clinics and the Tax Courts for pro se individuals to receive correspondence offering the opportunity of free legal services from a tax clinic.
Taxation With Representation: The Creation And Development Of Low-Income Taxpayer Clinics, T. Keith Fogg
Taxation With Representation: The Creation And Development Of Low-Income Taxpayer Clinics, T. Keith Fogg
T. Keith Fogg
This article provides a chronological history of low-income tax clinics in the United States from their inception in 1974 to the present. It discusses leaders in the tax clinic movement such as Stuart Filler, Janet Spragens and Nina Olson and their impact on the growth of tax clinics. In addition to individual leaders, several institutions played significant roles in shaping the development of tax clinics. Tax clinics developed parallel to and then in conjunction with legal service corporation offices and academic clinics. The article discusses the growth of tax clinics within the broader growth of poverty law and the academic …
Financial Disability For All, T. Keith Fogg, Rachel E. Zuraw
Financial Disability For All, T. Keith Fogg, Rachel E. Zuraw
T. Keith Fogg
The Internal Revenue Code has four discreet sections that allow late filing of claims and other documents under the circumstances described in those sections. The IRS has promulgated a procedural regulation that allows it to permit late elections under prescribed circumstances. Neither the Code sections nor the Regulation cover all of the circumstances in which taxpayers have a good excuse for missing a time frame. The current provisions have developed in an ad hoc manner. More ad hoc development of this area is possible as equitable tolling litigation seeks to open up time frames under the Code despite the efforts …
Low-Income Taxpayer Clinicians Meet With Service Representatives, T. Keith Fogg
Low-Income Taxpayer Clinicians Meet With Service Representatives, T. Keith Fogg
T. Keith Fogg
This short article appeared in 31(4) ABA Section of Taxation NewsQuarterly (Summer 2012), p. 16.
Systemic Problems With Low-Dollar Lien Filing, T. Keith Fogg
Systemic Problems With Low-Dollar Lien Filing, T. Keith Fogg
T. Keith Fogg
This article explains why the IRS policy of filing the notice of federal tax lien based primarily on a dollar criteria puts low-income taxpayers, who usually have low-dollar liens, in a worse position. It also proposes improvements on the current system.
Effectively Representing Your Client Before The Irs, 5th Edition, T. Keith Fogg, Editor-In-Chief, T. Fogg
Effectively Representing Your Client Before The Irs, 5th Edition, T. Keith Fogg, Editor-In-Chief, T. Fogg
T. Keith Fogg
"Effectively Representing Your Client Before the IRS is a comprehensive collection of everything a tax professional should know when dealing with the IRS. Written by some of the most experienced tax controversy lawyers in the United States, it not only provides an in-depth discussion of the law, but is replete with realistic examples and hundreds of practice tips to aid tax practitioners during all stages of representation before the IRS in controversy matters, including exam, appeals, Tax Court, refund actions, and collection matters. The two-volume reference also includes a companion CD-ROM. No tax professional should be without Effectively Representing Your …
Tax Collection: Procedure And Strategies, T. Fogg
Relief For Taxpayers From The Federal Tax Lien, T. Fogg
Relief For Taxpayers From The Federal Tax Lien, T. Fogg
T. Keith Fogg
No abstract provided.
Tax Collection: Procedure And Strategies, T. Fogg
Chapter 11, Section 10, T. Fogg
Handling A Case With Potential Criminal Problems, Including Dealing With Nonfilers, T. Fogg
Handling A Case With Potential Criminal Problems, Including Dealing With Nonfilers, T. Fogg
T. Keith Fogg
No abstract provided.