In Uncategorized on 10/20/2021 at 08:24

Bob Gover’s 1962 masterpiece has truly been a gift that keeps on giving me good headlines. And last night The Great Chieftain of The Jersey Boys gave us a reminder that losing your “S” may not happen even if the chops, add-ons and interest take you over the $50K cutoff for small case treatment.

Though you may try for the Matthew 7:13 treatment, when disputed tax only is less than $50K,  small-claimerhood in US Tax Court is reached only when Section 7463(f) is in play.

Briefly, that means Section 6015 innocent spousery, CDP in Section 6330 NITL (but not Section 6320 NFTL; watch it), and Section 6404(h) interest abatement where the amount of interest in dispute is less than $50K.

All others, it’s $50K total in dispute: tax, interest, add-ons, and chops.

Check out Frantic Frank’s Continuing Ed online lectures. No charge, and well worth your time.

And no, I don’t get any compensation for any of this, other than intangible spiritual benefits.


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