Income Taxes, Tax Returns, Tax Penalties

Ofrecimiento De Transacción: Oportunidad Para Resolver La Deuda Tributaria

Foodman CPAs & Advisors on 6/17/2024

El IRS emitió el Consejo Fiscal 2024-37, el 24 de abril de 2024, para informar a los contribuyentes que no pueden pagar su deuda tributaria completa o si pagar les causaría dificultades financieras, que deberían considerar...more

Offer In Compromise: Opportunity To Solve Tax Debt

Foodman CPAs & Advisors on 6/17/2024

IRS issued Tax Tip 2024-37, April 24, 2024, to inform taxpayers that can’t pay their full tax debt or if paying would cause financial hardship, that they should consider applying for an offer in compromise which is a program...more

Around the Country: Recent Cases in Tax Penalty Abatement

Kilpatrick on 5/24/2024

Introduction – What Is Tax Penalty Abatement? Audits can be an incredibly frustrating ordeal. From initial contact with tax authorities to digging up old financial records to possibly increasing tax liability, there are...more

Missing the Tax Court’s 90-Day Deficiency Deadline – Now What?

Rivkin Radler LLP on 4/24/2024

Over the years, I have observed there is only one thing that a taxpayer fears more than being notified by the IRS that their income tax return for a particular taxable year has been selected for audit, and that is being...more

IRS to Focus on High-Income Earners Who Have Not Filed Tax Returns Since 2017

Fox Rothschild LLP on 3/4/2024

The IRS expects to send out over 125,000 collection letters to high-income taxpayers who did not file one or more federal income tax returns between 2017 and 2021. As part of the new collection initiative, approximately...more

Consejo de Estado de Colombia: sanciones e intereses en déficit de autorretenciones

Holland & Knight LLP on 8/24/2023

El Consejo de Estado de Colombia en Sentencia de 19 de julio de 2023 (radicado 26209) concluyó que cuando se presenten déficit en las autorretenciones mensuales por impuesto sobre la renta frente al total de ingresos...more

Weekly IRS Roundup June 5 – June 9, 2023

McDermott Will & Emery on 6/13/2023

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

IRS Lacks Statutory Authority to Assess Certain Form 5471 Penalties

Freeman Law on 4/13/2023

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

Playing Battleship with the IRS: Assessing the Damages

Bilzin Sumberg on 4/7/2023

In a prior post, I discussed the dangers of playing Battleship with the IRS. Recently, taxpayers made a move and scored a hit with the Tax Court’s recently issued decision in Alon Farhy v. Commissioner, 160 T.C. No. 6 (April...more

Supreme Court Hands Taxpayers a Victory in FBAR Penalty Case

Cadwalader, Wickersham & Taft LLP on 3/22/2023

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

Major Win For Taxpayers: SCOTUS Limits FBAR Penalties to Per Report Not Per Financial Account

Polsinelli on 3/14/2023

After years of litigation, the United States Supreme Court, in Bittner v. United States, 598 U.S. ____ (2023), determined that the penalty for a non-willful failure to file a Report of Foreign Bank and Financial Accounts...more

Tax Court in Brief | Mulu v. Comm'r | Accuracy-Related Penalty and No Reasonable-Cause Excuse

Freeman Law on 1/30/2023

Summary: In this non-precedential opinion (see section 7463(b)), the Tax Court addresses whether or not to uphold an accuracy-related penalty assessed to taxpayer, Ashenafi Getachew Mulu (Mulu). Mulu hired David...more

Federal and California Taxpayer Relief: Reprieve From Wet Winter Weather

Farella Braun + Martel LLP on 1/25/2023

2023 started California off with weather that escapes recent memory. Rain, snow, and surf seemed unrelenting for the first two weeks of January. While this spell of winter storms has brought snow to our slopes and refilled...more

Tax Court in Brief | Decrescenzo v. Comm’r | Challenge to Notice of Deficiency and Penalties for Frivolous Arguments

Freeman Law on 1/16/2023

Taxpayer and petitioner, Joseph Decrescenzo (“Petitioner”) belatedly filed returns of income for seven years at issue (2007-2013). The IRS determined various differing deficiencies as to the years at issue and notified...more

Tax Court in Brief | Wondries v. Comm’r | Deficiencies for Deduction of Farm and Ranch Expenses; Hobby or Activity Engaged in For...

Freeman Law on 1/16/2023

Summary: Paul Wondries and Patricia Wondries (the Wondries) sought relief from the Tax Court to review the IRS’s determinations of deficiencies and accuracy-related penalties arising mainly from deductions for expenses...more

Tax Court in Brief | Mining v. Comm’r | Deficiency Determination and Penalties for Underreporting and Frivolous Arguments

Freeman Law on 1/9/2023

Summary: During 2016, Ryan Mining (Mining) was employed by Tasco, Inc. (Tasco), and it issued him Form W–2, Wage and Tax Statement, reporting wages of $116,000, no federal income tax withheld, Social Security tax withheld of...more

Tax Court in Brief | Castro v. Comm’r | IRS Compliance with Written Supervisory Approval Requirement for Accuracy-Related...

Freeman Law on 1/4/2023

Short Summary: After an examination by a Revenue Agent, the IRS issued to the taxpayers a notice of determination of income tax deficiencies, a tax addition, and an accuracy-related penalty. In closing the examination, the...more

Income Taxes › Tax Returns › Tax Penalties

Ofrecimiento De Transacción: Oportunidad Para Resolver La Deuda Tributaria

Offer In Compromise: Opportunity To Solve Tax Debt

Around the Country: Recent Cases in Tax Penalty Abatement

Missing the Tax Court’s 90-Day Deficiency Deadline – Now What?

IRS to Focus on High-Income Earners Who Have Not Filed Tax Returns Since 2017

Consejo de Estado de Colombia: sanciones e intereses en déficit de autorretenciones

Weekly IRS Roundup June 5 – June 9, 2023

IRS Lacks Statutory Authority to Assess Certain Form 5471 Penalties

Playing Battleship with the IRS: Assessing the Damages

Supreme Court Hands Taxpayers a Victory in FBAR Penalty Case

Major Win For Taxpayers: SCOTUS Limits FBAR Penalties to Per Report Not Per Financial Account

Tax Court in Brief | Mulu v. Comm'r | Accuracy-Related Penalty and No Reasonable-Cause Excuse

Federal and California Taxpayer Relief: Reprieve From Wet Winter Weather

Tax Court in Brief | Decrescenzo v. Comm’r | Challenge to Notice of Deficiency and Penalties for Frivolous Arguments

Tax Court in Brief | Wondries v. Comm’r | Deficiencies for Deduction of Farm and Ranch Expenses; Hobby or Activity Engaged in For...

Tax Court in Brief | Mining v. Comm’r | Deficiency Determination and Penalties for Underreporting and Frivolous Arguments

Tax Court in Brief | Castro v. Comm’r | IRS Compliance with Written Supervisory Approval Requirement for Accuracy-Related...

Section 6751(b) Penalty Approval Circuit Split

Weekly IRS Roundup September 19 – September 23, 2022

Weekly IRS Roundup September 12 – September 16, 2022

Weekly IRS Roundup September 6 – September 9, 2022

Federal Penalty Relief for Certain 2019 and 2020 Tax Returns Filed on or Before September 30, 2022

IRS Provides Dramatic Penalty Relief

Willful or Non-Willful? That Is the Question: IRS Rejects Non-Willful Certification

IRS Announces Penalty Relief for 2019, 2020 Tax Years

Income Taxes › Tax Returns › Tax Penalties

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