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
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 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