by Noah Green CPA CFE | May 17, 2026 | Sheepdog Tax Resolution Daily, Tax Resolution
A CP2000 is not a tax bill, not an audit, and not an invitation to file an amended return. It is a proposed change to the filed return based on information matching, with a response form, a deadline, and a defined administrative path that ends in either resolution or...
by Noah Green CPA CFE | May 17, 2026 | Sheepdog Tax Resolution Daily
A taxpayer who filed jointly in 2018, 2019, or earlier years may now find that the former spouse is divorced, separated, deported, deceased, or otherwise unavailable to provide a signature on a joint protective filing. The procedural question is whether the taxpayer...
by Noah Green CPA CFE | May 17, 2026 | Sheepdog Tax Resolution Daily
A protective Form 843 packet that does not identify the affected transcript entries is procedurally weak. The Treas. Reg. § 301.6402-2(b)(2) sufficiency requirements call for the grounds of the claim to be identified with enough specificity that the IRS examiner can...
by Noah Green CPA CFE | May 17, 2026 | Sheepdog Tax Resolution Daily
The Court of Federal Claims decided Kwong v. United States, 179 Fed. Cl. 382 (Fed. Cl. 2025), in a way that reopened a calendar most taxpayers and practitioners assumed had closed. The court read former IRC § 7508A(d), the federally declared disaster provision in...
by Noah Green CPA CFE | May 17, 2026 | Sheepdog Tax Resolution Daily
A protective claim is a procedural posture, not a separate document type. The vehicle for a Kwong v. United States protective claim, penalties and interest assessed off original (pre-postponement) due dates falling inside the COVID disaster window, is Form 843, the...
