Penalties and how to dispute them
From the first 972CG to a refund suit: which paper to file, in which order, and the clocks that run.
Form 843: claim or abatement
Why the same form does different things on a paid and an unpaid penalty, and which boxes the IRS reads.
Abatement request vs. refund claim
The two routes to removing a 1099 penalty, plus audit reconsideration as the third, with the IRS's own handling times.
Statute of limitations
Three clocks: assessment, refund and collection, for 972CG penalties and Form 945, and how examiners track them.
Penalties with no reasonable-cause defense
Which information-return penalties the IRS will not abate for cause, and what is left to argue.
Interest on penalties and Form 945
Start dates, the 21-day rule, and why interest on an employment tax is not abatable for IRS delay.
Doubt-as-to-liability offer
Form 656-L on a penalty you believe is wrong: no fee, no deposit, and two statutes it starts.
Taxpayer Advocate
When a stuck penalty, 147C or refund qualifies for TAS, and what Form 911 needs to say.
Reading a business account transcript
The transaction codes behind a penalty, a Form 945 balance, a freeze and a refund that went elsewhere.
Form 945 and backup withholding deposits
What goes wrong on the return that reports backup withholding, and how the IRS handles each case.
Form 945-X timing
File and pay before the next January 31 for an interest-free adjustment, and what happens to an adjusted return filed near the end of the statute.
The averaged FTD penalty
CP 207, the Form 945-A repair, and why the IRS averages your deposits when it cannot see them.
A second Form 945 for the same year
Duplicate, supplemental and superseding returns, and which one the IRS will process.
Deposit applied to the wrong form or year
Credit transfers, the letter to send, and how interest and penalties are recomputed once the money moves.
Unfiled Form 945
Why the IRS cannot prepare one for you under 6020(b), and what it does instead.
Where is my Form 945 refund?
The IRS's research timetable, tax offsets, Treasury offsets, and tracing a lost check.
Payees, vendors and third parties
When the IRS comes to a payer about someone else's account.
Letter 2625-C
The payer verification letter in a payee's underreporter case: what to confirm and how to answer.
IRS asking about a payee
Third-party contacts, what a payer must answer, and the records a summons can reach.
A levy on a vendor you paid
Forms 668-A and 668-W served on the payer: what is attached, for how long, and the penalty for ignoring it.
Business name change checklist
The entity unpostable problem: how a name change breaks the EIN match and how to fix it in order.
Deadlines, intake and processing
What happens to a return between the day it leaves you and the day the IRS acts on it.
When the IRS processes your 1099s
Campus completion dates, the two CP2100 runs each year, and what the gaps mean for a late filer.
Disaster relief and 1099 deadlines
What a FEMA declaration postpones, and the two things it does not: information returns and deposits.
Paper 1099 filing checklist
What survives IRS intake at the campus, and what gets a return bounced.
Letter 1865-C
Unprocessable paper 1099s and the 45-day rule for refiling without a late penalty.
Paper Form 8809
What happens to an extension request at Ogden, and the action codes that come back.
Form 10301
Opening the encrypted CP2100 or 972CG disc, and what to do when it will not open.
Regulations, Counsel and oversight
The layer under the manual: the regulations examiners apply, what Chief Counsel told them, and what the inspector general found.
Treas. Reg. 301.6724-1
The reasonable-cause regulation paragraph by paragraph, including the certified-W-9 safe harbor.
Treas. Reg. 31.3406
B-Notice timing, the W-9 you can rely on, exempt payees and the awaiting-TIN rule.
Chief Counsel memoranda
PMTA 2023-03 on the CP2100 and prior liability; CCA 200941012 on intentional disregard.
TIGTA findings
$13.3 billion not withheld by 182,075 payers, and the compliance group the IRS created in response.