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Why would you file a lawsuit against the IRS just to turn around and ask the District Court to dismiss it? A combination of impatience, new precedent, and personality changes left a Plaintiff looking for a way out of the Federal Court of Claims. Inte…
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Is there ever a good reason to hide something from the IRS? A recent opinion from the U.S. Federal Circuit Court of Appeals suggests that even the best of reasons won’t matter if a taxpayer is later found to have willfully failed to file FBAR forms…
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How many penalties can the IRS assess for a single missed form? That was the question before the Ninth Circuit Court recently in United States v Boyd. At least where an accurate FBAR report was filed late, the Court ruled that the one form and one vi…
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Many retired U.S. taxpayers don’t owe taxes at the end of the year. If their income from pre-tax retirement accounts and Social Security is offset by medical expenses or other allowable deductions, they may not have enough income to report, or any…
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Thousands of lawsuits settle out of court every year. These settlement agreements cover everything from slip and fall injuries to employment disputes. Figuring out whether you have to pay taxes on lawsuit settlements isn’t easy, or automatic. Here…
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Individuals and households earning more than $100,000 often have more complicated tax situations than their lower-earning counterparts. That could be especially true this year, as many wage-based employees are finding themselves working from home and…
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The amount taxpayers owe the IRS for unpaid taxes and penalties can add up quickly. Past-due penalties and statutory interest can turn even a modest unpaid tax debt into a significant problem, even for couples making a comfortable living. IRS tax ins…
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What opportunity should you have to dispute an IRS penalty before it is assessed? Should you be able to take the government to court? What about an administrative hearing by the IRS Appeals Office? In a recent motion to dismiss a taxpayer’s complai…
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Can the IRS assess penalties for willful FBAR violations if the taxpayer didn’t mean to lie to the government or hide assets? In a second opinion, one federal judge in Pennsylvania has ruled that a drug company’s CEO owed more than $1 million in…
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Recent changes to the IRS website acknowledged an existing policy to assess penalties for failure to file Form 3520 regarding foreign trust assets without considering taxpayer-provided reasonable cause statements. The website warns that taxpayers wil…
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