This Daily Tax Tip Spotify Podcast and/or WordPress Blog Post discusses the Tax Court reversal by the the Third Circuit. The Third Circuit held that the IRS Did Not Send Notice to Taxpayer’s Last Known Address.
The Third Circuit vacated a ruling in Gregory v. Commissioner, 2020 PTC 393 (3d Circuit 2020) by the Tax Court which found that the IRS had properly sent a notice of deficiency to a couple’s last known address by sending the notice to their former address, which the taxpayers’ CPA had incorrectly listed on their 2014 tax return, even though the taxpayers had subsequently listed their new address on IRS forms, although not on an official IRS change of address form.
The Third Circuit found that Form 8822 Change of Address, has not been consistently required to notify the IRS of an address change, and further found that the IRS had actual notice that the taxpayers had moved because, before the notice of deficiency was issued, the taxpayers’ CPA told an IRS agent conducting an audit that the taxpayers had moved.
Tax Tip Take Away:
Form 2848 Power of Attorney provides clear and concise notification of an address change by the taxpayer.
Please contact the office of Don Fitch Accountancy at (760)567-3110 or Email Don.Fitch@CPA.com if you have any questions or would like additional information.
DON FITCH, CPA
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Palm Desert, CA 92260
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