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Can You Go To Jail for Failing to Disclose Virtual Currency on a Tax Return or as Part of an Offer for a Collection Alternative?

Virtual currency, such as Bitcoin, continues to be a topic of interest for the IRS. Indeed, for the 2019 tax year, the IRS added for the first time a unique question to Schedule 1, Additional Income and Adjustments to...more

The Freeman Law Project – Episode 22 – Trump v. Vance - The Second Circuit Weigh In [Audio]

Jason B. Freeman and Matthew L. Roberts of Freeman Law, PLLC discuss the recent Second Circuit decision in Trump v. Vance. The case involves the ongoing battle between President Trump and the Manhattan District Attorney's...more

Taxpayer Wins Major Victory at Pleadings Stage on Trust Fund Recovery Penalty Case

Employees are required to withhold federal income and social security taxes from the wages of their employees.  If an employer fails to do so, the government will often assert the trust fund recovery penalty (“TFRP”) against...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

Clarifying the Contours of “Reasonable Compensation”

The law has always favored the term “reasonable.”  For example, the law affords protection against a negligence lawsuit if a person can demonstrate he or she acted as a reasonable person would have under similar...more

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