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What Is a Tenant's Duty to Pay Rent to the IRS After a Tax Levy?

Residential tenants often have little to no control over who they rent property from. But when a landlord runs into trouble with the IRS, it can be the tenant who is stuck paying. What is a tenant’s duty to pay rent to the IRS after a tax levy on a… Read More
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Categories: Tax / IRS Penalties
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Why You Need to Exhaust Administrative Claims in IRS Cases

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
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Categories: IRS Audits
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How Long Does the IRS Have to Sue for FBAR Penalties?

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
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Tax Court Says IRS Appeals Officers Not Subject to Presidential Appointments Clause

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
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Categories: Tax / IRS Penalties
IRS

Tax Court Says IRS Can’t Assess Penalties on Foreign Informational Returns, Again

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
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Categories: Tax / IRS Penalties
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Can You Request a Collection Due Process Hearing on FBAR Collections?

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
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Categories: FBAR
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IRS Can Collect FBAR Penalties from Estate Distributees, Court Says

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
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Categories: FBAR
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11th Circuit Rules Some (Not All) FBAR Penalties Unconstitutional

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
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Categories: FBAR
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Ninth Circuit Upholds Reckless FBAR Penalties Against Tax Preparer

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
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Categories: FBAR
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FBAR Negligence or Willfulness? Court Says Jury Must Decide

There have been a lot of cases in the last several years defining willfulness in the context of failures to file FBAR forms with the IRS. But a recent decision from the Northern District of California addresses the issue slightly differently. Instead… Read More
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Categories: FBAR