Section Newsletters

Articles From George E. Marifian

Proposed technical correction to Section 7430—Awarding of costs and certain fees By George E. Marifian Federal Taxation, September 2012 Section 7430, as currently drafted, allows Revenue Agents to take unreasonable initial positions in an examination with no adverse consequences for such unreasonable positions.
Section 7430—Awarding of costs and certain fees: Proposed technical corrections By George E. Marifian Federal Taxation, September 2011 Due to recent amendments, a current disparity in Section 7430 of the Internal Revenue Code gives rise to the result that, in practice, a taxpayer who settles an entire case in IRS Appeals even though he has received a 30-day letter, is entitled to no reimbursement.
Proposed technical correction to Section 7430 By George E. Marifian Federal Taxation, October 2010 This article addresses the need to harmonize Section 7430(c)(7)(B) with Section 7430(c)(2)(B) of the Internal Revenue Code.
Legislative agenda item: Proposed changes to Section 6694—Understatement of Taxpayer Liability by Return Preparer By George E. Marifian Federal Taxation, August 2008 These Comments address the need for amendments to recent changes to the tax return preparer penalty and the definition of tax return preparer in IRC Sections 6694 and 7701(a)(36).
Legislative agenda item: Proposed changes to Section 6694—Understatement of Taxpayer Liability by Return Preparer By George E. Marifian Federal Taxation, August 2008 These Comments address the need for amendments to recent changes to the tax return preparer penalty and the definition of tax return preparer in IRC Sections 6694 and 7701(a)(36).
Offer in compromise By George E. Marifian Federal Taxation, August 2007 These Comments are submitted partly in response to changes to the offer in compromise program (the “OIC Program”) enacted as part of the Tax Increase Prevention and Reconciliation Act of 2005 (Pub. L. No. 109-222) (“TIPRA”).
Message from the chair By George E. Marifian Federal Taxation, November 1999 In the last issue, we commented on the flurry of tax proposals being debated in Congress before the Labor Day Recess.
Message from the chair By George E. Marifian Federal Taxation, September 1999 Greetings and welcome to the new fiscal year for our section. I am pleased to report that we began the year with an excellent council meeting at Lake Geneva in June.

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