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Final Regulations Issued on Penalty Supervisory Approval

More than 25 years ago, Congress enacted Internal Revenue Code Section 6751(b) to protect taxpayers from the IRS using penalties as a bargaining chip in an effort to coerce taxpayers to settle. Generally, Section 6751(b)...more

IRS Authority to Assess Certain Foreign Information Return Penalties Restored by D.C. Circuit

The U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit) on May 3, 2024, reversed the U.S. Tax Court (USTC) in Alon Farhy v. Commissioner, No. 23-1179 (D.C. Cir. May 3, 2024) by holding that...more

Willful or Non-Willful? That Is the Question: IRS Rejects Non-Willful Certification

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

Same Statute, Same Form, Different Penalties: Welcome to FBAR Litigation

The "Report of Foreign Bank and Financial Accounts" (FBAR) penalty has been the subject of much litigation. This Holland & Knight alert focuses on the non-willfulness element of 31 U.S.C. ยง 5321(a)(5)(B). Both the U.S. Court...more

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