Letters from the IRS are often confusing, both to clients and to practitioners. So when the taxpayers in Robert Craig Colton and Alina Mazwin v Commissioner, T.C. Memo. 2021-44 (Apr. 21, 2021) (Judge Lauber) received a letter from the IRS saying “you do not owe us any money” for the...
Lesson From The Tax Court: Abatement Of Assessment Brings No Relief From Liability (TaxProf Blog) - Assessment of tax serves two critical functions. First, it reflects the IRS’s judgment of what taxes a taxpayers owes the government. It's the end of the tax determination process. Second, it’s a critical procedural pre-requisite for the administrative collection of a taxpayer's tax liability.














