There is a case called Sheridan, that requires judges to report the failure to report income to the proper authorities. Like Big Foot and the Lochness Monster, many people have heard of a Sheridan, but few have actually seen...more
Grajales v. Commissioner - In Grajales v. Comm’r of Internal Revenue, the United States Court of Appeals for the Second Circuit addressed whether the ten percent exaction under Section 72(t) (Exaction) is considered a...more
Harrington v. Commissioner - In Harrington v. Commissioner of Internal Revenue, George S. Harrington (Harrington) challenged tax deficiencies and fraud penalties assessed for tax years 2005 through 2010. Originally...more
In this bulletin, we highlight two recent federal court cases in which U.S. taxpayers won major victories against the United States with respect to their obligations to report non-U.S. accounts on FinCEN Form 114 – Report of...more
$50,000 or $2.72 million? Those are the penalty amounts for the non-willful failure to timely file to report foreign financial accounts at issue in U.S. v Bittner, which will be argued before the U.S. Supreme Court in...more
Recently, the U.S. Court of Appeals for the 5th Circuit ruled that the IRS could impose a penalty of $2.72 million for a taxpayer’s non-willful failure to report multiple foreign financial accounts on FBAR filings from 2007...more
The 35% penalty under I.R.C. section 6677 for failing to report a distribution from a foreign trust applies against a person who is both the beneficiary and grantor/owner of a foreign trust. At least, that is now the rule...more
Tax professionals are intimately familiar with certain reporting requirements under the Internal Revenue Code. Indeed, a failure to properly and timely report a position on a return where it is otherwise required may result...more
The IRS recently announced that high-income households will be the target of increased enforcement efforts after the agency reopened on July 15. The Service is aiming to increase compliance amongst high-income taxpayers...more
We have all heard the stories. Romeo and Juliet, Cleopatra and Mark Antony, and my personal favorite, Illsa Lund and Rick Blaine. Everyone loves a great love story. A developing romance leading to an emotionally pleasing and...more
The Internal Revenue Service (IRS) has signaled for years that it would eventually bring enforcement actions against individuals who failed to report cryptocurrency gains. It appears that “eventually” is over and that those...more
Taxpayers should take prompt action to assess their situation, yet move carefully before making representations or filings to the IRS. Over the past month, the Internal Revenue Service (IRS) has sent letters to over ten...more
The IRS produces a yearly list of Tax Scams known as the Dirty Dozen that Taxpayers may encounter. IRS reiterates that Tax Scams put Taxpayers at Risk when it releases its list of Dirty Dozen Tax Scams. These aggressive...more
Court rules that a "John Doe" summons to obtain confidential client records from a law firm isn’t barred by attorney-client privilege. On May 15, 2019, a district court in the Western District of Texas held that the...more