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...
by Noah Green CPA CFE | May 16, 2026 | Sheepdog Tax Resolution Daily, Tax Resolution
Discovering omitted income on a filed return is not, by itself, a crisis. It is a decision point. The right next step depends on what kind of income was missed, what year it covers, whether the IRS or the state has already noticed, how the omission affects the...
by Noah Green CPA CFE | May 16, 2026 | Sheepdog Tax Resolution Daily, Tax Resolution
IRS Form 1040-X is the individual amended-return form. It is used to correct a filed Form 1040, 1040-SR, or 1040-NR when the taxpayer’s filing status, income, deductions, credits, dependents, or tax liability changed. In a tax-resolution case, the harder...
