The recent Tax Court decision in Farhy demonstrates that clever and novel arguments can carry the day in complex tax litigation matters. In that case, the taxpayer stipulated that he: (1) had Form 5471 filing obligations...more
4/13/2023
/ Failure-to-File ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Lack of Authority ,
Settlement Agreements ,
Tax Abatement ,
Tax Court ,
Tax Liability ,
Tax Penalties ,
Tax Returns
In the federal income tax world, there are effectively two functions within the Internal Revenue Service (“IRS”). First, the IRS examines tax years and tax returns to determine whether the taxpayer has reported the correct...more
Federal tax penalties have always been an IRS priority. But, perhaps more so today than three decades ago. For example, in 1987, the IRS reported that it had assessed penalties of approximately $14 billion. Compare that...more
2/4/2021
/ Failure To Pay ,
Failure-to-File ,
Filing Requirements ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Tax Fraud ,
Tax Liability ,
Tax Penalties ,
Tax Planning ,
Tax Returns
I have previously written on the Bittner (E.D. Tex.) case in a prior Insight. Briefly summarized, the taxpayer, Mr. Bittner, was a dual citizen of both Romania and the United States. However, in 1990, he moved back to...more
10/10/2020
/ Appeals ,
Business Taxes ,
Calculation of Penalties ,
Civil Monetary Penalty ,
Congressional Intent ,
Cross Motions ,
Dual Citizenship ,
Failure-to-File ,
FBAR ,
Foreign Bank Accounts ,
Genuine Issue of Material Fact ,
Income Taxes ,
IRS ,
Reasonable Cause Defense ,
Reporting Requirements ,
Romania ,
Rule of Lenity ,
Summary Judgment ,
United States