Conference and Settlement Procedures
The following document contains information related to United States Civil Tax Procedures. Specifically, those procedures relating to conference and settlement are discussed, in regard to civil tax procedures. An introduction outlines the history of tax law embodied in United States Code, including the Sixteenth Amendment empowering Congress to tax U.S. residents and citizens. The following section explains the procedures relating to pre-conference and conference, including such aspects as practice before appeals, disclosure of information, representatives qualifies to practice before Appeals, disposition of powers of attorney, appeals conferences, recording of conferences and a variety of other aspects involved in the conference process. The subsequent section on settlements also conveys a number of issues related to such proceedings, including but not limited to case evaluation for settlement purposes, burden of proof, judicial attitude towards settlement, nuisance values settlements, partial settlements and settlements that impact later tax years. A conclusion makes an argument for taxpayers involved in conference and settlement proceedings to hire qualified representation due to the number and complexity of issues involved in such proceedings.
The Sixteenth Amendment to the U.S. Constitution was ratified in 1913, granting Congress the power to tax “incomes from whatever source derived, without apportionment among the several States, and without regard to any census of enumeration.” The Internal Revenue Code (I.R.C.) is today contained within Title 26 of the United States Code (U.S.C). Only Nevada does not impose a state income tax but all residents and/or citizens of the United States are required to pay federal income tax. Not all residents or citizens are required to file income tax, according to the requirements for filing in United States Code. Corporations are also r...