Latest Posts › Failure-to-File

Share:

IRS Lacks Statutory Authority to Assess Certain Form 5471 Penalties

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

Taxpayers’ Failure to File Form 3520 and Form 3520-A Results in Extended Statute of Limitations Period: the Cautionary Tale of...

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

How to Successfully Request IRS Penalty Relief

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

Court Strikes Down Largest Non-Willful FBAR Penalty Ever

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

4 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide