No Relief Under §7430 for Administrative Fees Where No Notice of Deficiency Issued and Appeals Ruled in Favor of Taxpayer
IRC §7430 is a provision in the tax law meant to allow taxpayers to recover costs when the IRS acts unreasonably. However, not all unreasonable conduct by the IRS that results in costs to the taxpayer will find redress in the provisions of IRC §7430, as the taxpayer in the case of Milligan v. Commissioner, TC Memo 2014‑259 discovered.
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