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Court Upholds IRS Penalti…

Court Upholds IRS Penalties on Unreported Foreign Wedding Gifts

A recent decision by the United States District Court for Northern California upheld the IRS’s penalties against a new bride for her unreported foreign wedding gifts, at least for now. Read More
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Categories: Tax News
Second Circuit Joins Cour…

Second Circuit Joins Courts Imposing Recklessness Standard for FBAR Penalties

Earlier this year, the Second Circuit Court of Appeals recently joined the growing consensus of courts imposing the recklessness standard to willful FBAR penalties. Read More
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Categories: FBAR, Tax News
2nd Circuit Agrees: IRS C…

2nd Circuit Agrees: IRS Can Assess Foreign Business Reporting Penalties

Over the last couple of years, the United States Tax Court has been ruling in favor of taxpayers facing assessments for failure to report their foreign business interests. Tax Court judges have issued rulings saying that lawsuits, rather than assessm… Read More
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Categories: Tax News
IRS Can’t Collect FBAR…

IRS Can’t Collect FBAR Penalty from Spy’s Widow, Ninth Circuit Says

IRS Can’t Collect FBAR Penalty from Spy’s Widow, Ninth Circuit Says What happens to FBAR penalties when a person dies? In a case that seemed to be pulled from a spy thriller, the Ninth Circuit Court recently held that, while the IRS could collect… Read More
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Categories: FBAR
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How Long Does a Restitution Lien Last?

If you are working to pay off unpaid restitution penalties, it can seem like the collection period will go on forever. Compounding interest and penalties, not to mention new liabilities incurred in the meantime can mean even regular payments don’t… Read More
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Categories: Tax / IRS Penalties
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Update: 11th Circuit Agrees Tax Court Can’t Hear FBAR Penalty Cases

Knowing where to file your tax challenge and which procedure to follow is essential to getting timely and effective relief when the IRS imposes incorrect assessments, penalties, or collections. A recent United States Circuit Court decision from the E… Read More
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Categories: Tax News
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Tax Court Divided on Equitable Tolling of TEFRA Partnership Adjustments

Under the 1982 Tax Equity and Fiscal Responsibility Act (TEFRA), one partner in a business can face substantial fines and penalties for the poor tax choices of another partner. A recent United States Tax Court case, North Wall Holdings, LLC v IRS, as… Read More
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Categories: Tax News
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8th Circuit Blocks IRS Blocked-Income Regulation

Complex international businesses file complicated tax returns, and the IRS often uses regulations to reallocate income among subsidiaries to reflect the company’s true income. But a recent 8th Circuit Court of Appeals decision says it can’t do th… Read More
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Categories: Tax News
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What Happens to Tax Liens After Bankruptcy and Foreclosure?

If you have fallen behind on several of your debts, tax liens may only be one part of your financial difficulties. When unpaid debts pile up, you could end up facing tax liens, bankruptcy proceedings and foreclosures, sometimes all at once. But what… Read More
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Categories: Tax / IRS Penalties
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Sixth Circuit Says Deficiency Petition Deadline is Not Jurisdictional

Everything in IRS tax collection comes with deadlines. This includes the 90-day tax deficiency petition deadline. But is there anything you can do if you miss that deadline and file your petition with the Tax Court late? The Sixth Circuit Court of Ap… Read More
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Categories: Tax News