Procedurally Taxing: What are the Most Litigated Issues and What’s Happening in Collection? (January 25, 2022)

Keith Fogg, Clinical Professor of Law at Harvard Law, has made available for download his article, “What are the Most Litigated Issues and What’s Happening in Collection?” published on the Procedurally Taxing blog. The article begins as follows:

This year the National Taxpayer Advocate took a new approach to calculating the most litigated issues in her annual report.  You can read about her approach starting on page 183 of the report.   Instead of just looking at the tried cases, which she does capture, she also looks at the cases in which taxpayers filed a Tax Court petition.  It’s all in how you define litigation.  Is it best measured by the relatively small number of cases that get tried and receive an opinion, i.e., looking at the end of the case where about 1% of the filed cases end up, or by looking at the filed cases in which taxpayers started litigation but for a variety of reasons did not follow it to a conclusion by trial and opinion?  Since she gives you both sets of data, it’s hard to complain no matter which set of information you prefer.

Click here to view Keith Fogg’s summary of “What are the Most Litigated Issues and What’s Happening in Collection?”.

Posted by Jessica Ji, Associate Editor, Wealth Strategies Journal.

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