U.S. Tax Law: Internal Revenue Code
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Internal Revenue Code

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USC Title 26 enacted through 2008

§ 7811. Taxpayer Assistance Orders

Authority to issue
In general
Upon application filed by a taxpayer with the Office of the Taxpayer Advocate (in such form, manner, and at such time as the Secretary shall by regulations prescribe), the National Taxpayer Advocate may issue a Taxpayer Assistance Order if -
the National Taxpayer Advocate determines the taxpayer is suffering or about to suffer a significant hardship as a result of the manner in which the internal revenue laws are being administered by the Secretary; or
the taxpayer meets such other requirements as are set forth in regulations prescribed by the Secretary.
Determination of hardship
For purposes of paragraph (1), a significant hardship shall include -
an immediate threat of adverse action;
a delay of more than 30 days in resolving taxpayer account problems;
the incurring by the taxpayer of significant costs (including fees for professional representation) if relief is not granted; or
irreparable injury to, or a long-term adverse impact on, the taxpayer if relief is not granted.
Standard where administrative guidance not followed
In cases where any Internal Revenue Service employee is not following applicable published administrative guidance (including the Internal Revenue Manual), the National Taxpayer Advocate shall construe the factors taken into account in determining whether to issue a Taxpayer Assistance Order in the manner most favorable to the taxpayer.
Terms of a Taxpayer Assistance Order
The terms of a Taxpayer Assistance Order may require the Secretary within a specified time period -
to release property of the taxpayer levied upon, or
to cease any action, take any action as permitted by law, or refrain from taking any action, with respect to the taxpayer under -
chapter 64 (relating to collection),
subchapter B of chapter 70 (relating to bankruptcy and receiverships),
chapter 78 (relating to discovery of liability and enforcement of title), or
any other provision of law which is specifically described by the National Taxpayer Advocate in such order.
Authority to modify or rescind
Any Taxpayer Assistance Order issued by the National Taxpayer Advocate under this section may be modified or rescinded -
only by the National Taxpayer Advocate, the Commissioner of Internal Revenue, or the Deputy Commissioner of Internal Revenue, and
only if a written explanation of the reasons for the modification or rescission is provided to the National Taxpayer Advocate.
Suspension of running of period of limitation
The running of any period of limitation with respect to any action described in subsection (b) shall be suspended for -
the period beginning on the date of the taxpayer's application under subsection (a) and ending on the date of the National Taxpayer Advocate's decision with respect to such application, and
any period specified by the National Taxpayer Advocate in a Taxpayer Assistance Order issued pursuant to such application.
Independent action of National Taxpayer Advocate
Nothing in this section shall prevent the National Taxpayer Advocate from taking any action in the absence of an application under subsection (a).
National Taxpayer Advocate
For purposes of this section, the term "National Taxpayer Advocate" includes any designee of the National Taxpayer Advocate.
Application to persons performing services under a qualified tax collection contract
Any order issued or action taken by the National Taxpayer Advocate pursuant to this section shall apply to persons performing services under a qualified tax collection contract (as defined in section 6306(b)) to the same extent and in the same manner as such order or action applies to the Secretary.

Tax Code (Internal Revenue Code) Section Index

U.S. GAAP by Codification Topic
105 GAAP Hierarchy
105 GAAP History

205 Presentation of Financial Statements
205-20 Discontinued Operations
210 Balance Sheet
210-20 Offsetting
220 Comprehensive Income
225 Income Statement
225-20 Extraordinary and Unusual Items
230 Statement of Cash Flows
250 Accounting Changes and Error Corrections
260 Earnings per Share
270 Interim Reporting

310 Impairment of a Loan
320 Investment Securities
320 Other-Than-Temporary Impairments, FSP FAS 115-2
320-10-05 Overview of Investments in Other Entities
320-10-35 Reclassification of Investments in Securities
323-10 Equity Method Investments
323-30 Investments in Partnerships and Joint Ventures
325-20 Cost Method Investments
330 Inventory

340-20 Capitalized Advertising Costs
350-20 Goodwill
350-30 Intangibles Other than Goodwill
350-40 Internal-Use Software
350-50 Website Development Costs
360 Property, Plant and Equipment
360-20 Real Estate Sales

410 Asset Retirement and Environmental Obligations
420 Exit or Disposal Cost Obligations
450 Contingencies
450-20 Loss Contingencies
450-30 Gain Contingencies
480 Redeemable Financial Instruments

505-20 Stock Dividends, Stock Splits
505-30 Treasury Stock

605 SEC Staff Accounting Bulletin, Topic 13
605-25 Revenue Recognition - Multiple Element Arrangements

715-30 Defined Benefit Plans - Pension
718 Share-Based Payment
730 Research and Development
730-20 Research and Development Arrangements

805 Business Combinations
810 Consolidation
810 Noncontrolling Interests
810 Consolidation of Variable Interest Entities, SFAS 167

815 Derivatives and Hedging Overview

820 Fair Value Measurements
820 Fair value when the markets are not active, FSP FAS 157-4
825 Fair Value Option

830 Foreign Currency Matters
830-20 Foreign Currency Transactions
830-30 Translation of Financial Statements
835 Interest
835-20 Capitalization of Interest
835-30 Imputation of Interest

840 Leases
840-20 Operating Leases
840-30 Capital Leases
840-40 Sale-Leaseback Transactions
845 Nonmonetary Transactions

855 Subsequent Events
860-20 Sale of Financial Assets, SFAS 166
860-50 Servicing Assets and Liabilities, SFAS 156

985-20 Costs of software to be sold

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