Here is a collection of the Top Ten Most Litigated Tax Issues from 2007 as determined by the National Taxpayer Advocate, Nina Olson. 

1. Collection Due Process hearings (IRC §§ 6320 and 6330);
2. Gross income (IRC § 61 and related Code sections);
3. Summons enforcement (IRC §§ 7602(a), 7604(a), and 7609(a));
4. Civil damages for certain unauthorized collection actions (IRC § 7433);
5. Frivolous issues penalty (IRC § 6673 and related appellate-level sanctions);
6. Failure to file penalty (IRC § 6651(a)(1)) and estimated tax penalty (IRC § 6654);
7. Trade or business expenses (IRC § 162(a) and related Code sections);
8. Accuracy-related penalty (IRC § 6662(b)(1) and (2));
9. Relief from joint and several liability for spouses (IRC § 6015); and
10. Family status issues (IRC §§ 2, 24, 32, and 151).

    We will discuss some of these most litigated issues in future posts and the types of cases that stem from each issue.  Be sure to check back often for those discussions.