In the late 1990s and early 2000s, the IRS was confronted with a proliferation of corporate transactions that it viewed as aggressive tax shelters. Relying on the authority Congress delegated through Section 6011(a), the IRS...more
6/13/2024
/ Administrative Procedure Act ,
Conservation Easements ,
Corporate Taxes ,
Easements ,
IRS ,
Proposed Regulation ,
Reporting Requirements ,
Tax Appeals ,
Tax Avoidance ,
Tax Court ,
Tax Penalties ,
Tax Shelters
The U.S. Tax Court (USTC) on April 3, 2023, issued its opinion in Alon Farhy v. Commissioner, which held that the IRS lacks authority to assess certain foreign-related information return penalties pursuant to Section...more
In Flint v. United States, 2022 WL 3593826 (Fed. Cl. 2022), the court held that the executors of an estate could not recover a six-figure "Title 26 miscellaneous offshore penalty" (MOP) the decedent paid to the Internal...more
9/1/2022
/ Audits ,
Breach of Contract ,
Foreign Bank Accounts ,
Income Taxes ,
IRS ,
Offshore Funds ,
Penalties ,
Remediation ,
Reporting Requirements ,
Self-Certification ,
Tax Penalties ,
Tax Returns ,
Willful Violations
One of the most highly litigated issues in U.S. Tax Court is whether taxpayers are liable for certain penalties, additions to tax or additional amounts (each, a "penalty" and collectively, "penalties"). This should come as no...more