A hearing is scheduled for September 11, 2023 for interested persons and organizations to provide testimony on proposed regulations on the timing and approval process for penalties. Section 6751(b) provides that...more
Many people, myself included, can sometimes be accused of poor penmanship. As our paperwork becomes more and more electronic, we write less and less down with pen and paper. However, a recent decision from the tax court may...more
On June 21, 2022, the United States Supreme Court agreed to hear a dispute involving split decisions among the circuit courts on non-willful penalties. The Fifth Circuit parted ways with the taxpayer friendly decision of the...more
6/23/2022
/ Failure-to-File ,
FBAR ,
Foreign Financial Accounts ,
Income Taxes ,
IRS ,
Penalty Reductions ,
Regulatory Violations ,
Reporting Requirements ,
Tax Court ,
Tax Evasion ,
Tax Penalties ,
Tax Planning
Although the government bears the burden of production for penalties, this often involves nothing more than showing that the penalties were properly assessed. Penalty relief is usually only given when the taxpayer can marshal...more
Starting any business has risk, and most businesses take time to become profitable. Unfortunately, the IRS sees multiple years of losses from a business as a red-flag that usually results in further scrutiny. That scrutiny...more
All kinds of penalties are being assessed by the Internal Revenue Service (IRS) against taxpayers, and more can be expected in the future. In 1954 there were 13 penalties in the Internal Revenue Code, and now there are more...more
The IRS is vigorously litigating cases involving conservation easements they believe are abusive. One such case was Plateau Holdings, LLC v. Comm’r, T.C. Memo 2020-93 (Plateau I). In that case the Tax Court denied the entire...more
12/10/2021
/ Conservation Easements ,
Defense Strategies ,
Fair Valuation ,
Good Faith ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Tax Court ,
Tax Deductions ,
Tax Liability ,
Tax Penalties
On November 30, 2021, the Fifth Circuit parted ways with the taxpayer friendly decision of the Ninth Circuit that non-willful penalties are capped at $10,000 per FBAR filing instead of the $10,000 per unreported bank account...more
12/1/2021
/ Enforcement Actions ,
FBAR ,
Foreign Bank Accounts ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Offshore Funds ,
OVDP ,
Reporting Requirements ,
Tax Court ,
Tax Evasion ,
Tax Liability ,
Tax Penalties ,
Tax Planning ,
Tax Returns