The Internal Revenue Service (IRS) sent thousands of taxpayers a letter, alerting them of an unauthorized inspection or disclosure of their tax return or return information by a former IRS contractor, Charles Littlejohn....more
The U.S. Tax Court recently held in SN Worthington Holdings LLC v. Commissioner, 162 T.C. No. 10 (2024), that the petitioning partnership had properly elected into the Bipartisan Budget Act of 2015 (BBA) procedures for the...more
6/3/2024
/ Audits ,
Bipartisan Budget Act ,
Corporate Taxes ,
Default ,
IRS ,
Jurisdiction ,
Partnerships ,
Tax Court ,
Tax Liability ,
Tax Returns ,
TEFRA
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
In Cotto-Vázquez v. United States, CIV. NO.: 16-2807 (SCC) (D.P.R. March 11, 2021), Miguel Ángel Cotto-Vázquez (Cotto),1 the former four-time Puerto Rican boxing champion, became involved in another fight. This time he faced...more
In Notice 2004-45, 2004-2 C.B. 33, the IRS put taxpayers who were asserting to be bona fide residents of the U.S. Virgin Islands (USVI) and who were not following the requirements of meeting the applicable bona fide residency...more
3/10/2021
/ Appeals ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Large Business & International Division (LB&I) ,
Puerto Rico ,
Remand ,
Residency Requirements ,
Statute of Limitations ,
Tax Court ,
Tax Returns ,
Virgin Islands
Virtual currency transactions are now a prime focus of Internal Revenue Service (IRS) scrutiny. The IRS has numerous information-gathering tools to enforce its taxing power, including summons, artificial intelligence, data...more
12/4/2019
/ AICPA ,
Criminal Investigations ,
Cryptocurrency ,
Digital Currency ,
FBAR ,
Financial Transactions ,
FinCEN ,
Internal Revenue Code (IRC) ,
IRS ,
Popular ,
Reporting Requirements ,
Suspicious Activity Reports (SARs) ,
Tax Planning ,
Tax Returns ,
Virtual Currency ,
Voluntary Disclosure