(2009). InSmith, the Court found it lacked jurisdiction to redetermine an IRC § 6707A penalty because the penalty did not fit the statutory definition of deficiency and because the IRS could assess and collect the penalty without issuing a statutory notice of deficiency. However, the Tax ...
Chameleon-like IRS revenue agents often change the definition of the trusts' intent depending on the situation they are facing. Nominees and alter egos are two common references to trustee/agents. With the planned destruction of all the trusts' assets and trustee/agents in place the trustee/...