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With hundreds of cases in the courts, the IRS is preparing at least its fourth settlement offer in syndicated conservation easement cases in recent years.

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Taxpayers and practitioners are unsure whether the CP53E notices they have received are scams or simply sent in error, a confusion heightened by the inclusion of a QR code.

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The IRS is reinstating the practice of issuing these letters in response to numerous informal comments from taxpayers and practitioners regarding the time required to process letter ruling requests and the scope of those requests.

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National Taxpayer Advocate Erin Collins explained what affected taxpayers need to do in response to the Court of Federal Claims’ holding that a taxpayer’s refund claim filing deadline was automatically extended by Sec. 7508A(d)(1) due to the COVID-19 disaster declaration.

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Taxpayers meeting eligibility rules can now use Form 907 to preserve their right to challenge ERC disallowances while the IRS continues its review.

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