News & Analysis as of

Failure-to-File Tax Returns

Mayer Brown

Relieved Taxpayers: US Tax Court Reaffirms that IRS Cannot Assess Failure-to-file Penalties

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Every parent remembers when their child learns the meaning of the word “no.” That moment often comes as a shock because, up until that moment, most children are models of obedience and unconditional trust. When children learn...more

Bowditch & Dewey

Death and Taxes – Deceased Taxpayers Still Waiting for Tax Refunds

Bowditch & Dewey on

The Internal Revenue Service recently acknowledged systemic problems processing tax returns for deceased taxpayers who are due to receive a tax refund. The National Taxpayer Advocate (TAS) reported that the IRS experienced...more

McDermott Will & Emery

Weekly IRS Roundup June 5 – June 9, 2023

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 5, 2023 – June 9, 2023...more

Freeman Law

IRS Lacks Statutory Authority to Assess Certain Form 5471 Penalties

Freeman Law on

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

Cadwalader, Wickersham & Taft LLP

Supreme Court Hands Taxpayers a Victory in FBAR Penalty Case

Taxpayers recently won a significant victory at the Supreme Court in a penalty case involving a non-willful failure to file a Report of Foreign Bank and Financial Accounts (“FBAR”) under the Bank Secrecy Act (the “BSA”)....more

Freeman Law

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

Freeman Law on

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

Freeman Law

Tax Court in Brief | Kemegue v. Comm'r | Additions to Tax for Failure to File

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Summary: In this non-precedential opinion (see section 7463(b)), the Tax Court addresses an addition to tax for failure to pay pursuant to section 6651(a)(1) and (2). During 2017 Kemegue lost his job and experienced multiple...more

Lowndes

Good News: IRS Grants $1.2 Billion in Penalty Relief for Taxpayers Impacted by Covid-19

Lowndes on

The senior living industry was hit hard by the Covid-19, and the IRS recently announced relief for people or businesses who filed their 2019 or 2020 tax returns late as a result. If your business was subject to failure to...more

McDermott Will & Emery

Weekly IRS Roundup September 6 – September 9, 2022

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 6, 2022 – September 9, 2022...more

Polsinelli

IRS Announces Relief From Penalties On Some 2019 And 2020 Tax Returns

Polsinelli on

The IRS just announced, in releasing Notice 22-36, that it will be automatically issuing an estimated $1.2 billion in refunds or credits related to failure to file penalties assessed against taxpayers on a broad range of 2019...more

Foodman CPAs & Advisors

How IRS Finds “Mismatches” Via Its Automated Compliance Programs

The IRS uses the information it collects to detect, prevent, and reduce noncompliance and fraud.  The US Government accountability Office (GAO) produced a Tax Administration Report on December 2020 (Better Coordination Could...more

Foodman CPAs & Advisors

High-Income Individuals And Corporate Tax Returns Are Targets Of IRS Additional Funding Program

The 2022 discretionary funding request (request) made by the Biden Administration will invest in a “fair and robust” tax system that includes tax compliance enforcement directed at High Income and High Net  Worth Individuals...more

Freeman Law

How to Successfully Request IRS Penalty Relief

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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

Foodman CPAs & Advisors

Comisionado del IRS envía un Mensaje Importante a los Contribuyentes de Altos Ingresos que No Declaran

El 3 de diciembre del 2020, el IRS publicó “Cómo el IRS prioriza el trabajo de cumplimiento en los no declarantes de altos ingresos a través de esfuerzos nacionales e internacionales” en el Estudio titulado “Closer Look”.  El...more

Foodman CPAs & Advisors

IRS Commissioner Hylton sends an important message to high income non-filers

Foodman CPAs & Advisors on

On December 3, 2020, the IRS published  “How the IRS prioritizes compliance work on high income non-filers through national and international efforts” in the Closer Look.  ...more

Foodman CPAs & Advisors

IRS has a Commitment to Service US Taxpayers and Enforce Collections Compliance

According to the Internal Revenue Code, Taxpayers have three obligations: (1) to file timely returns; (2) to file accurate returns; and (3) to pay the required tax voluntarily and timely. ...more

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