What if I am pulled over and suspected of driving under the influence?
Summary: In this non-precedential opinion (see section 7463(b)), the Tax Court addresses whether or not to uphold an accuracy-related penalty assessed to taxpayer, Ashenafi Getachew Mulu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
Summary: This case involves taxpayers, Calvin Lim and Helen Chu (together, “Petitioners”) federal income tax liabilities for 2016 and 2017 with respect to a disallowed charitable contribution deduction....more
Tax Litigation: The Week of August 29th, 2022, through September 2nd, 2022 Sparta Pink Property, LLC v. Comm’r, T.C. Memo. 2022-88 | August 29, 2022 | Lauber, J. | Dkt. No. 12114-20 Pressman v. Comm’r, T.C. Summ. Op....more
Section 6721 provides the IRS with authority to impose civil penalties against taxpayer-employers who fail to timely file correct information returns (e.g., Forms W-2/W-3 and Forms 940/941). Under section 6721’s three-tiered...more
IRS Tax Penalties and the Tax Professional Reliance Defense - No one wants to pay federal taxes. And this truism applies more so with respect to federal tax penalties. Accordingly, clients often call upon their tax...more
Foreign Gifts and IRS Reporting - U.S. persons who receive gifts or bequests from foreign persons beware—these gifts or bequests may need to be reported to the Internal Revenue Service (“IRS”). The consequences for failing...more
A recent Tax Court decision addresses the “reasonable cause” standard — a frequent issue in the IRS-penalty context. As the case demonstrates, whether a taxpayer acted with reasonable cause and in good faith is determined on...more
According to the IRS Manual, reasonable cause for abating penalties is based on all the facts and circumstances of a Taxpayer’s situation. IRS will consider reasons which establish that a Taxpayer used all ordinary care and...more
In the US, Taxpayers “self-assess and voluntarily” pay taxes. The IRS position is that Voluntary Compliance occurs when a Taxpayer makes a “good faith” effort to meet the Taxpayer’s tax obligations as defined in the Internal...more
There are times when Taxpayers will attempt to use the “it is not my fault” argument as a defense relating to IRS penalties. Taxpayers might argue that they relied on guidance from a tax professional or from a tax software...more
According to the IRS, accuracy related penalties remain the number one most litigated tax issue. The Internal Revenue Code authorizes the IRS to impose penalties if a Taxpayer is negligent or disregards tax rules and...more