Most Litigated Tax Issues

The National Taxpayer Advocate 2009 Annual Report to Congress list the following as the most litigated tax issues.  You can find the report here.

1.  Appeals from Collection Due Process (CDP) Hearings Under Internal Revenue Code Sections 6320 and 6330

2.  Summons Enforcement Under Internal Revenue Code Sections 7602, 7604, and 7609

3. Trade or Business Expenses Under Internal Revenue Code Section 162 and Related Section

4.  Gross Income Under Internal Revenue Code Section 61 and Related Sections

5.  Accuracy-Related Penalty Under Internal Revenue Code Section 6662

6.  Frivolous Issues Penalty Under Internal Revenue Code Section 6673 and Related Appellate-Level Sanctions

7.  Civil Actions to Enforce Federal Tax Liens or to Subject Property to Payment of Tax Under Internal Revenue Code Section 7403

8.  Failure to File Penalty Under Internal Revenue Code Section 6651(a)(1) and Estimated Tax Penalty Under Internal Revenue Code Section 6654

9.  Family Status Issues Under Internal Revenue Code Sections 2, 24, 32, and 151

10.  Relief from Joint and Several Liability Under Internal Revenue Code Section 6015