No Porsche Required: Why Every Taxpayer, Not Just The One Percent, Deserves An Advocate In Their Corner.

Contributed by: Odi Odian, Rule 19-220, Student Attorney in the Low Income Taxpayer Clinic

What should have been a simple settlement conference instead devolved into hours of preparation with no agreement in sight. This wasn’t due to a lack of effort or errors by either party, but rather the case’s increasing complexity. To ensure the client received the best possible outcome, more work had to be done. Throughout the process, I found myself wondering: where would this case be now had the taxpayer sought legal advice from the beginning?

While complex, this case is far from unique. Many individuals come to Low Income Taxpayer Clinics (LITC) long after the window for ideal legal steps has closed. This isn’t a critique of the taxpayers; after all, they cannot do what they do not know. Instead, it is a necessary reminder to everyday taxpayers that free resources like LITCs exist, and they can save people thousands of dollars.

If I asked you to describe a tax law case, you would likely picture a billionaire hiring a high-priced attorney who drives a Porsche, and someone paid millions to convince the IRS that no fraud was committed (even when maybe it was). While those cases exist, they do not represent the work of an LITC. We represent individuals within specific income thresholds who simply cannot afford the liability the IRS claims they owe.

Most of our cases involve local “mom and pop” taxpayers who are working hard to make ends meet and have only a basic understanding of tax law. In these instances, professional legal assistance can be the difference between owing hundreds of dollars instead of thousands. More importantly, it allows a taxpayer to sleep easier at night, knowing they have an advocate in their corner who speaks the language of the Internal Revenue Code. Taxes are inherently frustrating, but utilizing pro bono resources early on can make the burden just a little bit lighter.

Reflecting on Tax

Contributed by: Thomas Fowlkes, Rule 19-220, Student Attorney in the Low Income Taxpayer Clinic

It was Justice Holmes who said “Taxes are what you pay for a civilized society”. On its face, it can be read as though we pay taxes to keep the lights on, funding schools, roads and medical services. Yet, the system of how the means for these services is collected can quickly become confusing and technical. When Justice Holmes wrote this quote in 1904, there was no Federal income tax. Today, however, the federal tax system is one of the most complex regulatory frameworks in existence, governing not only how revenue is raised, but also influencing economic behavior, investment decisions, and wealth distribution.

The work we do at the Low-Income Taxpayer Clinic is vital in providing a means for everyday people to be heard. For many taxpayers, the complexity of this system creates barriers that effectively prevent them from asserting their rights or understanding their obligations. Because of this, I was extremely eager to learn and develop myself as an attorney in both understanding how the system works.

What I was not prepared for, however, was the extent to which these cases would stay with me outside of the clinic. Sitting across from clients who felt persecuted and angry with the system, I began to notice a gap between how the system is supposed to operate and how it is experienced by the people subject to it. This was heartbreaking for me to see. Many taxpayers arrive believing the system is rigged against them and without a clear understanding of what went wrong. This was often not the result of indifference, but rather of navigating a system that is highly technical and unforgiving of mistakes. In several instances, my clients had done nothing wrong; rather, government or employer error had placed them in difficult situations that left them with no clear path forward. At the start, it was certainly difficult at times to reconcile the idea of a fair system with the problems my clients were facing.

Over time however, seeing these issues resolved and watching clients move from confusion to relief had a clear impact on me. The moment when a client realizes they have options, and that their situation is not as final as they believed, is one that I found genuinely rewarding. Coming into the clinic, I was unsure whether representing taxpayers was a field I would pursue long term. Through these experiences, I found that helping clients navigate a system that had caused them stress and uncertainty was both meaningful and motivating. I have since come to understand that guiding taxpayers through a system that is often intimidating and confusing aligns closely with what I feel is the broader role of the legal profession: to provide clarity, advocacy, and access to justice. It is exactly this that our clinic is able to offer people every day.

My time at the clinic has been instructive in ways I did not anticipate. It has not only deepened my understanding of the tax system, but also strengthened my confidence and capabilities as a developing attorney. I look forward to seeing the work my peers at the clinic will do in practice, as well as applying the skills and lessons I learned here to my own clients moving forward.

Practice Is Not Perfect

Contributed by: Garri Edwards, Rule 19-220, Student Attorney in the Low Income Taxpayer Clinic

Law school teaches students how to find answers. It is less explicit about what to do when you don’t have one yet or when the honest answer is that you cannot help at all. Those two situations come up constantly in live client representation, and they are far more uncomfortable than any exam.

Working in the Low Income Taxpayer Clinic (LITC) forced me to confront both. The clients who come through this clinic are not hypotheticals. They have real IRS notices, real deadlines, and real stakes often involving back taxes, penalties, and confusion about rights they didn’t know they had. Walking into a client meeting with a half-formed answer isn’t just an academic shortcoming. It can cause genuine harm.

When a client asks a direct question and you don’t have a confident answer, there is a strong pull to bridge the gap, to hedge in a way that sounds like knowledge, or to answer the question you can answer rather than the one being asked. This impulse isn’t dishonest, exactly. It comes from a genuine desire to be useful while prioritizing the attorney’s comfort over the client’s need for accurate information.

In the clinic, I learned to resist that comfort. Saying “I don’t know the answer to that, but I will find out and follow up with you by a specific date” is not an admission of failure. It is what competent, ethical representation actually sounds like. Honest uncertainty, paired with a clear commitment to follow through, tends to build more trust than confident approximation.

Harder than not knowing an answer is recognizing when a client’s situation falls outside what you are authorized or equipped to handle. The LITC has a defined scope, and not every person who walks through the door fits within it. Some cases involve representation that student attorneys cannot provide. Some present complexity that requires more experienced counsel. The real emotional weight is telling someone you cannot take their case, particularly when they have taken considerable effort to be there. This is also where scope of representation becomes concrete in a way it never is in a classroom. You are not doing a client a favor by absorbing them into a process that cannot serve them well. Recognizing that limit is a professional obligation, not a personal shortcoming.

Client-centered advocacy has a specific demand that only becomes clear in practice: it requires organizing every decision around the client’s goals, rather than the attorney’s comfort. That means being honest about limits instead of papering over them. It means taking the time to understand what a client is really asking before answering a different, easier version of the question. It means following through on every commitment. And it means accepting that sometimes the most client-centered thing you can do is acknowledge that you are not the right person for the job.

The practical skills of tax representation were always going to be part of this experience. What I did not anticipate was how much I would learn about the ethics of presence: how to be genuinely useful to someone, rather than just technically engaged with their problem. That lesson did not come from a textbook. It came from sitting across the table from people who needed real help and having to be honest about what I could and couldn’t give them.

What to Do If You Owe the IRS and Cannot Pay

Contributed by: Dawn Chukwurah, Rule 19-220, Student Attorney in the Low Income Taxpayer Clinic

For many taxpayers, receiving a letter from the Internal Revenue Service (IRS) stating that taxes are owed can be stressful and confusing. Many people assume that if they cannot immediately pay their tax debt, they have no options. However, the IRS provides several programs that allow taxpayers to resolve their tax liabilities in a manageable way.

Understanding these options can help reduce stress, prevent additional penalties, and help taxpayers take control of their financial situation.

Why Do People End Up Owing Taxes?

Taxpayers may owe taxes for a variety of reasons. In many cases, the issue is not intentional wrongdoing but rather confusion about tax rules or unexpected financial circumstances.

Some of the most common reasons people owe taxes include:

• Failure to report all income on a tax return
• Receiving multiple sources of income, such as freelance work or side jobs
• Incorrectly calculating tax credits or deductions
• Withholding too little tax from paychecks
• Self-employment income where taxes were not paid throughout the year

Many taxpayers also receive notices from the IRS after the agency compares the information reported on a tax return with documents it receives from employers and financial institutions, such as W-2s and 1099 forms. If the IRS finds a discrepancy, it may send a notice proposing additional taxes owed.

When taxpayers receive these notices, it can feel overwhelming. However, it is important to remember that the IRS offers several options that may help resolve the issue.

Installment Agreements

One of the most common options available to taxpayers who owe money to the IRS is an installment agreement. An installment agreement allows taxpayers to pay their tax debt over time through monthly payments rather than paying the entire balance at once.

For taxpayers who owe smaller balances, the IRS may allow a streamlined installment agreement, which typically does not require the taxpayer to submit detailed financial information. This option allows taxpayers to set up a payment plan that can extend for several months or even several years, depending on the amount owed.

Installment agreements can be helpful because they allow taxpayers to remain compliant with the IRS while gradually paying down their tax debt. However, interest and penalties may continue to accrue while payments are being made.

Offer in Compromise

In certain situations, taxpayers may qualify for an Offer in Compromise (OIC). This program allows taxpayers to settle their tax debt for less than the full amount owed.

The IRS generally approves an Offer in Compromise only when it determines that the taxpayer cannot reasonably pay the full balance within the time the IRS has to collect the debt. To determine eligibility, the IRS evaluates the taxpayer’s financial situation, including income, expenses, assets, and overall ability to pay.

For example, taxpayers with limited income and minimal assets may qualify for this program if paying the full amount would create significant financial hardship.

Although the Offer in Compromise program can provide substantial relief, it is important to note that not every taxpayer will qualify. The IRS carefully reviews each application before accepting an offer.

Currently Not Collectible (CNC) Status
 In some cases, taxpayers may be unable to make any payments toward their tax debt due to financial hardship. In these situations, the IRS may place the taxpayer in Currently Not Collectible (CNC) status.

When a taxpayer is placed in CNC status, the IRS temporarily suspends collection efforts, meaning it will not pursue actions such as wage garnishment or bank levies. However, the tax debt does not go away, and penalties and interest may continue to accrue.

To qualify, the taxpayer must demonstrate that their income is so insufficient to cover even basic living expenses. The IRS will review the taxpayer’s financial information to determine eligibility. CNC status can provide immediate relief, but the IRS may periodically review the taxpayer’s financial situation to determine whether collection can resume.

Penalty Abatement

When taxpayers owe taxes, they are often charged additional penalties and interest. These penalties can increase the amount owed and make it more difficult for taxpayers to resolve their tax debt.

Fortunately, the IRS provides options for requesting that penalties be removed or reduced. This process is known as penalty abatement.

One common option is First-Time Penalty Abatement (FTA). Taxpayers may qualify if they have a history of filing and paying taxes on time but failed to comply in a single tax year. To qualify, the taxpayer generally must have filed all required tax returns, and have paid, or arranged to pay, any outstanding tax due.

Taxpayers may also request reasonable cause penalty relief if circumstances beyond their control prevented them from meeting their tax obligations. Examples of reasonable cause may include serious illness, natural disasters, or reliance on incorrect professional advice.

While penalty abatement does not eliminate the underlying tax debt, it can significantly reduce the total amount owed.

The Importance of Responding to IRS Notices

One of the biggest mistakes taxpayers make when dealing with tax debt is ignoring IRS correspondence. When a taxpayer receives a notice from the IRS, it is important to carefully review the information and respond promptly.

Ignoring IRS notices can result in additional penalties and interest. In more serious situations, the IRS may initiate collection actions such as placing a lien on property, garnishing wages, or levying bank accounts.

Instead of ignoring IRS notices, taxpayers should review the notice carefully, verify whether the information is correct, and explore the available options for resolving the issue.

Seeking Professional Help

Tax issues can be complex, and many taxpayers are unsure where to turn for help. Fortunately, some organizations assist individuals who are struggling with tax problems.

Low Income Taxpayer Clinics (LITCs) provide free or low-cost legal assistance to taxpayers who are experiencing disputes with the IRS. These clinics help taxpayers understand their rights and may assist with issues such as installment agreements, Offers in Compromise, and IRS audits.

Additionally, organizations such as the CASH Campaign of Maryland (www.cashmd.org) offer free tax preparation services for eligible individuals. These programs can help taxpayers accurately file their returns and avoid future issues with the IRS.

Final Thoughts

Owing money to the IRS can feel overwhelming, but taxpayers should remember that they have options. Programs such as installment agreements, Offers in Compromise, and penalty abatement exist to help taxpayers resolve their tax debts in a manageable way.

The most important step taxpayers can take is to address the issue early. By reviewing IRS notices carefully, seeking assistance when needed, and exploring available resolution options, taxpayers can avoid additional penalties and regain control of their financial situation.

Taking proactive steps toward resolving tax issues can make tax season far less stressful and help taxpayers move forward with greater confidence.

Becoming A ” Tax Person”

Contributed by: Kaleab Tekleyohannes, Rule 19-220, Student Attorney in the Low Income Taxpayer Clinic

When I started at the University of Baltimore School of Law, I did not expect to go into tax. It was the class I assumed I would simply just go through the motions, not the area that would end up shaping my career goals. That changed when I joined UBalt’s Low‑Income Taxpayer Clinic, where student‑attorneys represent low‑income taxpayers in real disputes with the IRS and state tax authorities. Walking into clinic for the first time, I thought I was signing up for a good experiential credit, not realizing what I was stepping into.

In the clinic, I worked on various types of problems that had been hanging over clients for years. Those issues were never just numbers on a transcript, they showed up as potential wage garnishments, refund offsets, and constant worry about what the government would do next. My role as a student‑attorney included interviewing clients, reviewing IRS notices, reviewing transcripts, and researching the Internal Revenue Code and procedural rules to figure out what options were actually on the table.

The clinic also pushed me to grow as a communicator and case manager. Most clients were understandably not well versed in tax law, so I had to learn how to explain complicated tax rules in plain language. On the practice‑management side, I got into the habit of logging every call and email in Clio, properly filing folders and documents which will help me in my career since many firms use this software. The clinic also helped me improve my time management skills. I have become much more proficient in properly organizing my days so that I Can balance both clinic and my three classes.

Now reaching towards the end of my time at the LITC, tax has gone from an afterthought to an important part my career plans. The clinic not only gave me practical experience and confidence but turned me into a “tax person.”

The conflict: a perspective of the professional rules clashes with human emotions

Contributed by: Sammy Patnaik, Rule 19-220, Student Attorney in the Low Income Taxpayer Clinic

During the sixth week of the Spring 2026 semester, I was given the opportunity to lead my own IRS settlement conference. Professor Shih asked the student attorneys if anyone was willing to take it on. The conference was scheduled for week seven, which meant the selected student would have just seven days to prepare. Despite the tight timeline, I volunteered immediately. I wanted the responsibility and the challenge.

After meeting with Professor Shih and Professor Alberotanza, I learned that the case centered on the very doctrine we had been studying all semester: § 6015 of the Internal Revenue Code, commonly known as “Innocent Spouse” relief. Section 6015 provides a defense for a spouse who is jointly and severally liable for a tax debt but is not actually responsible for the underlying deficiency. If successful, liability shifts to the spouse who caused the tax problem.

The legal elements of an innocent spouse claim were not the primary difficulty. The real issue was ethical. A § 6015 claim inherently creates a conflict of interest between spouses. By design, one spouse must argue that the other bears sole responsibility. Under the rules of professional responsibility, a conflict exists when a lawyer’s representation of one client is materially limited by responsibilities to another client. Even if a conflict is waivable, it does not disappear; it continues to exist and must be carefully managed. Waiver is only permissible in certain circumstances (ie. if the attorney can still competently and diligently represent both clients).

This case also highlighted an important distinction between a client’s objective interests and the decisions the client chooses to make. A client’s objective best interest is determined from a legal and financial standpoint, not by personal preference or loyalty. Here, the wife’s objective interest was to pursue § 6015 relief and sever her obligation of liability. The husband’s objective interest was the opposite: to keep her jointly liable so the IRS would have two potential sources of collection.

Complicating matters, the wife did not want to pursue innocent spouse relief. Out of loyalty, she preferred to “fall on her sword” and remain liable alongside her husband. The husband, in contrast, wanted her to seek relief because he acknowledged that the tax liability stemmed from his conduct. Despite their mutual goodwill, their objective interests remained directly adverse.

This distinction can be difficult to grasp: a client’s interests and a client’s decisions are not the same. Even if a spouse promises not to pursue § 6015 relief, that promise does not eliminate the conflict. Circumstances change. Clients reconsider. In fact, the wife changed her position twice while attempting to preserve harmony in the marriage. But no matter how many times she reconsidered, the underlying conflict remained.

Ultimately, I had to refrain from representing both spouses. It was not an easy decision. The experience required careful ethical analysis, clear communication, and empathy. Although it was difficult, ensuring that each spouse received independent representation was the correct course of action. In the end, we arranged alternative counsel for the spouse we could not continue to represent.

A Student’s Perspective of the IRS: A Shifting Image of an Adversary

Contributed by: Jeremy Wilcox, Rule 19-220, Student Attorney in the Low Income Taxpayer Clinic

As first year students, we are introduced to and then frequently reminded of a central condition of this profession: it is adversarial. Our professors drill this concept home in mock arguments, advocacy seminars, and various readings on trial strategy. We are taught, in the most professional capacity possible, with all due respect and necessary decorum, that there are fights to be had. I never enjoyed that.

I remember feeling indifferent during in-class hypotheticals where I was positioned against other students. As my classmates were concerned with “winning” these simulated experiences, I was disinterested in the competition. I would do what was required to get a grade, but I was not going to be contentious with people I would likely be working around not just for the next 3 academic years, but possibly for the rest of my career. I had accepted a mindset that when there were stakes beyond a grade, I would be willing to be adversarial. Thanks to the clinic, that time came sooner rather than later.

There is a storied history of resentment towards taxes entrenched in the depths of American culture. Imagine my excitement upon acceptance into the Tax clinic, at the chance to take on the very edifice of that discontent, the IRS itself, fighting for the little guy against a labyrinthine, unfeeling body with the singular goal of taking people’s money. Needless to say, there was romanticism to be had, despite the mundanity inherent in the idea of discussing taxation.

Finally, I could conceptualize an adversary.

And for several weeks, they were a perfect adversary. I had been tasked with preparing a response to a refund claim that was rejected, or as the obtuse language read, “disallowed.” This verbiage, as well as several accompanying paragraphs and specific citations, was the exact sort of detached, uncaring, boiler plate reasoning I had envisioned. So dutifully, I began researching what they were saying and how to respond.

As first year students, we are given hours of instruction on research. We are taught where to conduct it, sources and authority levels, and organizational strategies. For as many hours as were lectured on the topic, at least twice as many were spent in the chase of the perfect case or the exact statute to sell an argument. We were taught that it is a foundational portion of the practice.

Naturally, that extended into the work required for the clinic. But this new adversary did not make it hard. The IRS’ disallowance language was unclear, but I quickly discovered the majority of their rules, decision-making strategies, and relevant cases were accessible on their own website, with links to articles and publications explaining them. While the sharing of resources may not be procedurally atypical, this is the first time I experienced it with that level of accompanying guidance. This easy-to-use material was the first in a series of experiences that chipped away at the image I had built in my head of my opponent.

The second was a series of phone calls with the Practitioner Priority Line. I had been warned of the notorious hold times that occur on those phone calls. I was fully prepared to spend hours with automated music on a loop in my ear, only eventually broken by the angst of a call center employee in the weeds of their shift.

But in each instance, neither hold was longer than an hour. I spoke with two agents, and both were cordial, direct, and mostly forthcoming. They were normal people, who sounded as purposeful about answering the phone as I was about calling. Granted, these were only two calls, and could have been anomalous compared to the woes my classmates had expressed about their experiences, but my understanding of this adversary I had imagined continued to shift.      

The final humanization occurred when our clinic took a trip to the DC Tax court. There we observed court proceedings between the IRS, the respondent, and a large power management corporation, the petitioner. While the particularities of the case were and still are murky to me, what was clear was the attitudes and presentation styles of each party.

The corporate counsel had prepared a lengthy series of PowerPoint slides. They delivered them with an abundance of confidence that, based upon the responses of the judge, was hedging into arrogance. Combine that with an argumentative and at times condescending demeanor, and they were doing all of the things I had seen professors tell my classmates not to do. This was in direct contrast to the IRS attorney.

He needed time to prepare himself. He had to pivot around mistakes in his materials. The judge spoke to him as if he were a student working his way to answer that he wasn’t certain was correct. The man seemed more to be an overworked referee than someone truly adversarial.

If this agent was representative of the whole, he was certainly not the picture I had conceptualized behind the material I had spent the semester trudging through. And so, my perception of this adversary changed again, and the romanticized zeal for “taking them on” waned.

On the whole, this semester was a series of lessons in the reality of dealing with a large-scale government entity that I am not sure I would have gotten had I not taken the clinic. While it is still easy to frame the large faceless institution of “the IRS” as an adversary, the hostility I had begun with was misplaced. As I worked through my cases and saw more of the agency in action, I realized I had misunderstood what adversarial meant. Through this semester of tax advocacy, it has become clear the key is meticulous examination of the law against opposition, not just competitive, loud argument.

What A Carceral Visit Taught Me About Client-Centered Lawyering

Contributed by: Rylie Johnson, Rule 19-220, Student Attorney in the Low Income Taxpayer Clinic

Our LITC’s collaborative learning approach recently gave me the opportunity to accompany one of my fellow student attorneys to a client visit at the Maryland Correctional Institution for Women.

When initial attempts to contact the client were unsuccessful, an in-person meeting became necessary. Following our LITC’s procedure, we received visitation approval from the warden and gathered hard copies of all potentially relevant documents, as electronics were not permitted. Equipped with those materials and a pen, we were screened and allowed into the facility.

Going into the meeting, I did not know what to expect. Although we had a general understanding of our client’s tax issue, we were unfamiliar with a carceral setting and the limitations it can pose to effective client-centered lawyering. Communication barriers, limited resources, procedural hurdles, and reduced autonomy can affect all clients, but in this case, these challenges were compounded by the carceral setting.

Our interaction with the client was both pleasant and impactful. Initially, I was taken aback to learn that she had not received any of our mail correspondence and was unaware of our meeting prior to our arrival. The warden notified her of our meeting after we had already arrived. Although she knew that she needed legal assistance, she was under the impression that her case was not being actively worked on. This revelation highlighted the practical limitations that we were facing and called for flexibility.

While we were able to gather helpful information, our client noted that she has kept all of her tax records and every piece of correspondence she received from the IRS. Had she known about our visit, she would have brought this documentation with her. Although we came prepared with return envelopes in case she needed to mail us anything, she explained that her file was nearly an inch thick. Because of the facility’s procedures, she could not return to her cell to retrieve the documents, and even if she had, we lacked access to a scanner or any secure way to copy and return her originals. It was disheartening that her diligent record-keeping was to no avail due to the breakdown in communication and the procedural barriers that prevented her from having a fair opportunity to share the materials.

Additional challenges became evident as we began discussing her specific tax issues. Our client is seeking to recover the Economic Impact Payments (stimulus checks) that were issued during the COVID-19 pandemic. The checks were unable to be issued due to an identify-theft concern. The IRS requested that she verify her identity, but the process could not be completed from within the carceral setting. Our client attempted to comply with the IRS’s request by providing the information she did have available to her. However, she was unable to meet all the specified requirements and did not receive any reply from the IRS. At the time, she had been working with a social worker who assisted her with filing her tax returns and communicating with the IRS, but that support ended when the social worker was promoted and no longer remained involved in her case.

Despite actively seeking a resolution, our client had been left in the dark regarding the status of her tax situation. She expressed frustration with prior efforts, which left her believing her case had reached a dead end, and also with her lack of autonomy in addressing her own affairs while in the correctional facility. She was relieved to obtain representation through the LITC, where her tax concerns are now being addressed. She shared that she hopes to recover her stimulus payments to assist her family by covering her father’s medical expenses. I was touched by our client’s attitude; despite her frustrations, she continually expressed gratitude for our visit and assistance, and her focus on helping her family highlighted her resilience and kindness.

This visit emphasized that flexibility, empathy, and thorough preparation are key components of client-centered lawyering, particularly in carceral settings where barriers serve to limit a client’s ability to participate in their own case. No two clients are exactly the same, so each case offers an opportunity to learn. I saw firsthand the practical challenges justice-involved clients face. While we were ultimately able to gather the information necessary to move toward resolving her case, the failure to inform our client of our visit or the state of her matter, the inability to retrieve her documents, and the lack of access to a document scanner all posed threats to providing efficient and thorough representation. This experience has taught me the adaptability required to serve clients effectively, regardless of the barriers they encounter.

Preparing for Tax Day: April 15

Contributed by: Motunrayo Akinloye, Rule 19-220, Student Attorney in the Low Income Taxpayer Clinic

Top Mistakes People Make When Filing Their Taxes and How To Avoid Them

For millions of Americans, tax season brings significant stress. Navigating tax filing, preparation, and payments can be daunting, particularly when balancing work, family, and life’s daily commitments. I once struggled to grasp tax law myself, but gaining a basic understanding made all the difference, highlighting just how valuable tax knowledge can be. Before we examine common tax filing errors, let’s start with a quick overview of tax fundamentals.

What are taxes, and why are they necessary?

• Taxes are mandatory payments collected by governments to fund public goods and services that benefit everyone. Understanding how taxes work is essential for managing your current and future finances.

Main Types of Taxes:

• Sales Tax: Added to the price of goods and services at the time of purchase.
• Property Tax: Levied on real estate, such as land and buildings.
• Individual Income Tax: Tax on wages, salaries, investment income, and other personal earnings.
• Corporate Income Tax: Tax on business profits.
• Payroll Tax: Collected by employers from employees’ wages to fund social programs like Social Security and Medicare.
• Excise Tax: Applied to specific goods, such as gasoline, tobacco, or alcohol.
• Estate and Gift Tax: Imposed on the transfer of wealth, either after someone passes away (estate tax) or as a gift during their lifetime (gift tax).
• Capital Gains Tax: All profits from selling assets (stocks, real estate, crypto, etc.)

Income Taxes in the U.S.

• Federal Tax: Everyone in the U.S. pays this tax to the federal government.
• State Tax: Many people also pay taxes to their state government. Not all states impose an income tax, so this varies by location.

What are tax Brackets?

• Income is divided into brackets, and each bracket is taxed at a different rate. As you earn more, only the portion of your income within each bracket is taxed at that bracket’s rate. This means you pay higher rates on higher earnings, but not all income is taxed at the same percentage.

Common Tax Return Errors

Although tax laws can be complex, many tax return errors are simple and easy to avoid. Here are the most common ones:

1. Filing too early or too late: Taxpayers should avoid both premature and late filing. Filing before all necessary tax documents are received risks mistakes and processing delays. Also, missing the tax deadline can result in penalties, interest, and extra fines for late payments.
2. Missing or inaccurate Social Security numbers (SSNs). Each SSN on a tax return must match exactly as it appears on the individual’s Social Security card. It is important to verify the SSN to ensure accuracy, as mismatches can result in processing delays or prevent you from receiving a refund.
3. Misspelled names: The name provided on a tax return must match exactly with the name on the individual’s Social Security card.
4. Entering information inaccurately: Wages, dividends, bank interest, and other income received reported on a return should be entered carefully. This includes any information needed to calculate credits and deductions. While tax software helps prevent calculation mistakes, always review your return for accuracy.
5. Incorrect filing status: Selecting the wrong filing status is a common error for taxpayers. The filing status you choose—Single, Married Filing Jointly or Separately, or Head of Household—impacts your tax bracket, deductions, and eligibility for certain credits. If you are unsure which applies, the IRS’s Interactive Tax Assistant (ITA) can help you determine the correct status, particularly in situations where more than one status may fit. For example, a separated or legally divorced parent supporting a dependent child might qualify for both Single and Head of Household (HOH) statuses. Typically, HOH provides a more favorable standard deduction and tax brackets than Single. The ITA guides users through questions about their living situation, marital status, and dependents to determine qualification for HOH. Tax preparation software can also help minimize errors when selecting your filing status. 
6. Reporting Incorrect or Missing Income: All income streams, including freelance work and investments, must be reported. The IRS receives copies of your W-2s and 1099s, so omitting any may result in an audit.
7. Math mistakes: Math errors are among the most common mistakes in tax returns. These can involve simple addition or subtraction mistakes, as well as more complex calculation errors. Taxpayers should always double-check their math, though tax preparation software usually handles calculations automatically. Such mistakes can delay refunds or result in IRS notices.
8. Figuring credits or deductions: Credits such as the Earned Income Tax Credit, Child and Dependent Care Credit, Child Tax Credit, and Recovery Rebate Credit are often miscalculated. The Interactive Tax Assistant (ITA) can help determine eligibility, while tax software calculates the correct amounts and completes necessary forms. Taxpayers should review their final return to confirm the correct placement of credits and deductions.
9. Incorrect bank account numbers: For refunds, direct deposit is quickest, but only if accurate banking information is entered. Taxpayers must carefully input the correct routing and account numbers on their return to prevent payment issues.
10. Unsigned forms: A tax return is invalid if not signed. Typically, both spouses must sign a joint return, though exceptions apply, such as members of the armed forces or other taxpayers with a valid power of attorney. Filing electronically and using a digital signature can help prevent this oversight before submitting to the IRS.

For efficient tax filing, the IRS suggests e-filing and opting for direct deposit. IRS Free File and volunteer organizations like the CASH Campaign (www.cashmd.org) provide free assistance with tax preparation. By carefully reviewing your tax return for common errors and using the appropriate tools or resources, you can avoid unnecessary delays, minimize your chances of receiving IRS notices, and receive any refund you are owed as quickly as possible. Careful preparation pays off, giving you peace of mind and confidence that your tax filing is complete and accurate. Stay diligent and utilize available assistance to make tax season stress-free.

The 90-Day Clock: What Taxpayers Need to Know About Notices of Deficiency and Deadlines

Contributed by: Marina Tsikitas, Rule 19-220, Student Attorney in the Low Income Taxpayer Clinic

For tax professionals, the statutory notice of deficiency is a familiar but unforgiving document. Once the IRS mails a valid notice of deficiency, the taxpayer generally has 90 days (150 days if the notice is addressed to a person outside the United States) to petition the U.S. Tax Court.[1] If the petition arrives even one day late and no exception applies, the court will dismiss the case, and the taxpayer loses the chance to be heard.

During my work in the University of Baltimore Low-Income Taxpayer Clinic, I learned just how easy it is for that deadline to go wrong. One client received a notice of deficiency that clearly listed a response deadline of October 9^th. When I counted 90 days from the notice date myself, I landed on October 6^th. On paper, the IRS had given the taxpayer three extra days. That extra time would save them if they filed by October 9^th, but the mismatch shows how fragile these timelines are, especially for people who do not have representation and may not file until it is already too late.

The “last day to petition” and what it really means

Congress knows that most people are not counting days on a calendar. In 1998, it amended I.R.C. § 6213(a) in the Internal Revenue Service Restructuring and Reform Act to require the IRS to print the “last day” to petition on each notice of deficiency and to treat any petition filed by that printed date as timely.[2] The idea was simple: taxpayers should be able to rely on the date on the notice instead of doing their own deadline math.

The IRS followed suit in its own guidance. The Internal Revenue Manual (I.R.M.) explains that an incorrect “last day to file petition with the U.S. Tax Court” does not invalidate the notice. Instead, Tax Court jurisdiction turns on the 90th (or 150th) day after the notice is mailed or, if later, the last day printed on the notice. [3]

In practice, that rule protects taxpayers when the IRS gives too much time. If the Code says the 90-day deadline falls on October 6^th, but the notice says October 9^th, a petition filed on October 9^th is still timely. At the Clinic, we don’t assume the printed date is right. We always count forward 90 days from the mailing date and compare it to the “last day to petition” on the notice. When those dates do not match, we treat it as a red flag and talk with the client about filing as early as possible.

Is the 90-day deadline “jurisdictional”?

For years, the Tax Court and most courts of appeals treated the 90-day deadline as a strict jurisdictional rule. If the petition was late, the court said it had no power to hear the case, no matter how compelling the reason.[4]

In Hallmark Research Collective v. Commissioner, decided shortly after the Supreme Court’s decision in Boechler, the Tax Court held that § 6213(a)’s deadline is jurisdictional and not subject to equitable tolling.[5]

Things started to shift with Culp v. Commissioner. There, the Third Circuit held that the 90-day period in § 6213(a) is a claims-processing rule, not a jurisdictional bar, and that equitable tolling can apply.[6] Commentators and the National Taxpayer Advocate have noted that many Tax Court cases are dismissed each year as untimely, so Culp has the potential to open the courthouse doors for taxpayers who missed the deadline for reasons outside their control.[7]

Other courts of appeals and the Joint Committee on Taxation have recognized this trend. The Joint Committee’s description of H.R. 5349 notes that courts in several circuits now treat the deficiency deadline as non-jurisdictional and subject to equitable tolling.[8] Under the Golsen rule, the Tax Court follows those appellate decisions in cases that would be appealable to those circuits.[9]

What the Tax Court Improvement Act would change

The Tax Court Improvement Act (H.R. 5349) aims to make the rules consistent and fair. According to the Joint Committee on Taxation, the bill would explicitly allow the Tax Court to apply equitable tolling to the 90- day deadline in § 6213(a), no matter where the taxpayer lives or which circuit would hear the appeal.[10] It would also amend § 7459(d) so that if the court dismisses a case solely because equitable tolling does not apply, that dismissal would not count as a decision on the deficiency. The taxpayer could still choose to pay and pursue a refund in another court.[11]

A recent tax-policy update notes that on October 3^rd, 2025, the House Ways and Means Committee unanimously reported H.R. 5349 out of committee. The same update explains that the bill would “amend Tax Code section 6213(a) to permit the Tax Court to apply equitable tolling in deficiency cases” and adjust § 7459(d) so taxpayers denied equitable tolling can still seek a refund in district court or the Court of Federal Claims.[12]

As of this writing, Congress has not enacted H.R. 5349. For most taxpayers, the 90-day rule still operates as a hard wall.

What taxpayers and practitioners should do right now

Until Congress changes the law, taxpayers and practitioners need to treat these deadlines as deadly serious.

1. Recheck the date. Do not rely solely on the date printed on the notice. Independently count 90 (or 150) days from the notice date under § 6213(a). Calendar both dates. If they differ, treat the earlier one as the real danger point, even though the statute lets you rely on the later printed date.
2. Educate clients and community members. Low-income and unrepresented taxpayers often assume that the government-printed date is both correct and flexible. The National Taxpayer Advocate has stressed that a timely petition is what gives the Tax Court jurisdiction in the first place and has urged Congress to clarify that equitable tolling applies in deficiency cases.[13]

In the end without any action from Congress, the lesson is simple: Always check the deadline yourself. Don’t rely solely on what’s printed on the notice. Because if that date is wrong the IRS doesn’t bear the cost – you do.

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[1] I.R.C. § 6213(a)

[2] I.R.C. § 6213(a) (last sentence), as amended by Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. No. 105-206, § 3463, 112 Stat. 685, 764–65; H.R. REP. NO. 105-364, pt. 1, at 63 (1997); S. REP. NO. 105-174, at 90 (1998); STAFF OF J. COMM. ON TAXATION, 105TH CONG., GENERAL EXPLANATION OF TAX LEGISLATION ENACTED IN 1998, at 109–10 (Comm. Print 1998).

[3] I.R.S. INTERNAL REVENUE MANUAL § 4.8.9 (Jan. 10, 2023).

[4] See STAFF OF J. COMM. ON TAXATION, 119TH CONG., DESCRIPTION OF H.R. 5349, THE “TAX COURT IMPROVEMENT ACT” 8 (JCX-40-25) (2025).

[5] Hallmark Research Collective v. Commissioner, 159 T.C. 126 (2022)(holding that the 90-day deadline to file a deficiency petition under I.R.C. § 6213(a) is jurisdictional and not subject to equitable tolling, distinguishing Boechler; see Boechler, P.C. v. Commissioner, 596 U.S. 199 (2022) (holding that the 30-day deadline to file a CDP petition under I.R.C. § 6330(d)(1) is non-jurisdictional and subject to equitable tolling).

[6] Culp v. Commissioner, 75 F.4th 196 (3d Cir. 2023) (holding that § 6213(a)’s 90-day deadline is a non-jurisdictional claims-processing rule and is subject to equitable tolling, reversing the Tax Court’s dismissal).

[7] See Sonya C. Bishop & Marc Levey, Third Circuit Holds Tax Court’s 90-Day Petition Deadline Is Not Jurisdictional, Temple 10-Q (Apr. 10, 2024), https://www2.law.temple.edu/10q/third-circuit-holds-tax-courts-90-day-petition-deadline-is-not-jurisdictional; NAT’L TAXPAYER ADVOCATE, 2023 ANNUAL REPORT TO CONGRESS, supra note 7.

[8] JCX-40-25, supra note 8, at 8–9.

[9] Golsen v. Commissioner, 54 T.C. 742, 756–57 (1970), aff’d, 445 F.2d 985 (10th Cir. 1971) (adopting the rule that the Tax Court follows precedent of the court of appeals to which the case is appealable when that precedent is squarely on point).

[10] JCX-40-25, supra note 8, at 9–10.

[11] Id. at 10.

[12] Sullivan & Cromwell LLP, Tax Policy Update – November 17, 2025 (Nov. 17, 2025), https://www.sullcrom.com.

[13] NAT’L TAXPAYER ADVOCATE, Purple Book: Legislative Recommendations to Strengthen Taxpayer Rights 45–48 (2024).