A Conversation with the Director of the Montana Department of Revenue

In the past year, the Director of the Montana Department of Revenue (“DOR”), Brendan Beatty, spoke to the Taxation Committee of the Montana State Bar Association, of which I am the Chairman. Director Beatty was appointed Montana DOR Director by Governor Greg Gianforte in 2021. Director Beatty previously served for over 20 years as legal…

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When Can a Taxpayer Appeal to US Tax Court?

I am at times approached by taxpayers who “want to go to court” to challenge their federal income tax[liability. Such taxpayers may be chagrined to learn that while the ability to have a court hear their tax case definitely can lay in their future, there are typically multiple steps that taxpayers must follow before ending…

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Montana Pharmacy Paid Too Much Rent Says US Tax Court

Plentywood, MT pharmacy rent expenses. The US Tax Court recently heard a case where a Montana pharmacy located in Plentywood, Montana, population 1,700, paid rent for a building owned by the same people that owned the pharmacy. While rent is typically a deductible expense, that is not necessarily the case when the parties are closely…

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Fake Tax Notices

Taxpayers who owe delinquent taxes to the IRS or have tax liens on their property receive many different tax notices from the IRS in an attempt to collect. However, taxpayers may also receive other official looking notices that appear to be tax notices, but that are not from the IRS. A copy of one such…

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Taxpayers Have Limits in Collection Due Process Hearings

What is a Collection Due Process Hearing? A Collection Due Process Hearing (“CDP”) is an informal hearing with an  Appeals Officer from the IRS Independent Office of Appeals, provided by the Internal Revenue Code, to permit taxpayers to challenge the process the IRS has employed in imposing and collecting taxes. For example, a taxpayer is…

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