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Rev proc 2021-5 Form: What You Should Know

Exempt Status Determination Letter Application and Issuance. Jan. 4, 2021. Federal Tax. Tax Notes The IRS has published (Rev. Pro. 2021-1) revised procedures for issuing opinion and advisory letters on the form of  Exempt Status Determination Letter Application and Issuance Jan. 4, 2022. Federal Trade Commission In its March 13, 1996, decision in Covington v. Trans World Airlines Inc., 844 F.2d 1337 (7th Cir. 1988), the U.S. Court of Appeals for the 7th Circuit invalidated an IRS notice sent to Covington stating “A taxpayer who files an amended return shall only be liable for the amount which he could have deducted if he filed his return by the due date.” The court considered the tax law to be written on “a paper mountain” of exemptions and exemptions in the tax code for which filing requirements are not necessary.  The Covington decision has been considered influential in the recent decisions of other federal courts to uphold IRS guidance to taxpayers on whether an increase in withholding is necessary to pay federal income taxes because an increase in tax liability does not cause a taxpayer to face a tax liability more than once.

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