by Noah Green CPA CFE | May 17, 2026 | Sheepdog Tax Resolution Daily, Tax Resolution
The distinction between criminal and civil tax exposure on an unreported-income matter is rarely the question the taxpayer asks first. The question taxpayers usually ask is “Will I get in trouble if I correct this?” The accurate answer is that the...
by Noah Green CPA CFE | May 17, 2026 | Sheepdog Tax Resolution Daily, Tax Resolution
Most amended returns are amendment work. A few are tax-resolution cases that happen to involve a Form 1040-X. Confusing the two is one of the most common procedural mistakes in this practice area, and it usually shows up the same way: the taxpayer files Form 1040-X...
by Noah Green CPA CFE | May 17, 2026 | Sheepdog Tax Resolution Daily, Tax Resolution
The voluntary-correction-versus-waiting question is a strategic decision, not a moral one. The taxpayer who has discovered a prior-return error has three options: correct it voluntarily through a Form 1040-X, wait and respond if and when the IRS contacts the taxpayer...
by Noah Green CPA CFE | May 17, 2026 | Sheepdog Tax Resolution Daily, Tax Resolution
A missed Form 1099-B is one of the most common 1040-X triggers and one of the easiest to handle badly. The IRS receives the 1099-B directly from the broker, runs information matching against the filed return, and surfaces any mismatch through the Automated...
by Noah Green CPA CFE | May 17, 2026 | Sheepdog Tax Resolution Daily, Tax Resolution
The voluntary-amendment question is one of the most consequential decisions in a tax-resolution matter. It is not “Can I amend?” or “Should I file Form 1040-X?” It is “Given what I now know about a prior return, and given that the IRS has...
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...
