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Weekly IRS Roundup December 14 – December 18, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 14 – December 18, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

December 14, 2020: The IRS released Notice 2020-88 updating and amplifying procedures for Phase III of the section 48A advanced coal credit.

December 16, 2020: The IRS issued Revenue Ruling 21-01 providing various rates for determining the issue price of certain debt instruments issued for property.

December 16, 2020: The IRS issued Notice 21-01 delaying mandatory e-filing of Form 4720 by private foundations and announcing certain other changes.

December 18, 2020: The IRS released TD 9932 containing final regulations under Section 162(m) related to the employer deduction for certain employee remuneration in excess of $1 million.

December 18, 2020: The IRS released Internal Revenue Bulletin 2020-52, dated December 21, 2020, containing the following highlights: Rev. Rul. 2020-81 (Administrative); TD 9912 (Administrative); TD 9933 (Exempt Organizations); TD 9934 (Income Tax); TD 9935 (Income Tax).

December 18, 2020: The IRS released Practice Units on “Determining Liability Allocations” and “Recourse vs. Nonrecourse Liabilities” relating to partnership audits.

December 18, 2020: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Special thanks to Brian Moore in our Washington, DC, office for this week’s roundup.




Tax Court Announces New Case Management System to Go Live Before New Year’s

We previously reported on the US Tax Court’s (Tax Court) announcement that it was changing its case management system, DAWSON (Docket Access Within a Secure Online Network). This morning, the Tax Court issued a press release confirming the launch of DAWSON on December 28, 2020. Temporary credentials for taxpayers and practitioners already registered for electronic access will be sent no later than December 28, 2020, and will be valid for seven days. Expanded guidance on using DAWSON, including FAQs, will be available shortly on the Tax Court’s website.




Tax Court to Update Case Management System

The US Tax Court (Tax Court) recently announced upcoming changes to its case management system. DAWSON (Docket Access Within a Secure Online Network), named after former Tax Court Judge Howard A. Dawson, Jr., who passed away in 2016, is expected to be active by the end of 2020.

To facilitate the transition to DAWSON, the Tax Court’s current e-filing system will become inaccessible and all electronic files will become read-only beginning at 5:00 pm EST on November 20, 2020. Cases will remain electronically viewable, but no documents may be e-filed during this time. Importantly, no orders or opinions are anticipated to be issued during the transition.

Due to the lack of e-filing during the transition, Tax Court judges are trying to avoid setting deadlines that fall within this period. If a filing is required, it must be done the old-fashioned way on paper and by mail, with a proper certificate demonstrating service on the opposing party.

Notable improvements in DAWSON include:

  • Electronic filing of petitions and payment of filing fee
  • More user-friendly interface
  • Web-based, mobile-friendly and fully integrated system.

Practitioners should be on the lookout for an email from the Tax Court to set up their new account on DAWSON.

Practice Point: DAWSON will represent a significant upgrade for Tax Court practitioners. The addition of e-filing for petitions is particularly noteworthy as taxpayers and their representatives will not have to worry about potential problems and delays associated with physically mailing petitions to commence a case in Tax Court.




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