Important Developments in the World of Tax Procedure and Collection

Over the last year, there have been a number of important developments in the world of tax procedure and collection that every practitioner needs to be aware of. In some instances, the IRS and the courts have made attempts to clarify the law, such as in the area of dealing with the collection issues that are likely to arise with respect to criminal restitution payments as well as what few rights a taxpayer may have in stopping the foreclosure of his personal residence. In other situations, the IRS and the courts have made the practice of law in this area a trap for the unwary. What is crystal clear, however, is that the unending battle between the IRS and tax practitioners in the controversy area is alive and well, and it is imperative that tax practitioners keep abreast of the latest developments in order to properly protect their clients' rights and to avoid malpractice claims down the road.