When it feels like the IRS isn’t treating you fairly, it can be tempting to immediately turn to the courts for help. However, by law, you need to exhaust administrative claims in IRS cases before you can file a complaint in federal court. The recen… Read More

It can sometimes feel like an IRS audit or tax assessment can take forever, leaving taxpayers to wonder how long the IRS has to sue for FBAR penalties. A recent case coming out of the federal District Court in the Eastern District of New York shows t… Read More

Does the President of the United States have the exclusive power to appoint or remove IRS Appeals Officers? In a January 29, 2025, opinion which seemed to almost anticipate the new administration’s actions in other areas of the government, the Tax… Read More

The Tax Court has paved the way for the U.S. Supreme Court to determine whether the IRS has the authority to assess penalties on informational returns disclosing interests in foreign corporations. Rejecting the DC Circuit’s reversal of an earlier d… Read More

The penalties imposed for failure to file a Foreign Bank Account Reporting form (FBAR) can be substantial. The IRS has many mechanisms to collect on those debts. If you have received a notice of collection efforts, can you request a collection due pr… Read More

They say that nothing is certain except death and taxes. A recent decision by the United States District Court for the Southern District of New York says, between the two, taxes win. The judge granted the IRS authority to collect FBAR penalties from… Read More

Penalties for willful failure to file reports of foreign financial accounts – commonly called FBARs – are some of the highest civil penalties the government can impose. But until now, no court had been willing to say those fines were excessive. I… Read More

The Ninth Circuit – known as one of the most taxpayer friendly of the federal circuit courts – has joined many other courts in holding that reckless violations of the Bank Secrecy Act were sufficient to uphold willful FBAR penalties. The Court af… Read More