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How to Contest an IRS Notice of Tax Levy
June 13th, 2025
Receiving an IRS Notice of Tax Levy can be stressful, especially when it is inaccurate or you do not have the ability to pay your unpaid taxes. When that happens, you need to know how to contest an IRS notice of levy of unpaid tax liabilities, includ…
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Categories: Tax / IRS Penalties
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What Is a Tenant's Duty to Pay Rent to the IRS After a Tax Levy?
May 9th, 2025
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…
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Categories: Tax / IRS Penalties
Why You Need to Exhaust Administrative Claims in IRS Cases
April 29th, 2025
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…
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Categories: IRS Audits
How Long Does the IRS Have to Sue for FBAR Penalties?
March 11th, 2025
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…
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Tax Court Says IRS Appeals Officers Not Subject to Presidential Appointments Clause
February 10th, 2025
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…
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Categories: Tax / IRS Penalties
Tax Court Says IRS Can’t Assess Penalties on Foreign Informational Returns, Again
January 9th, 2025
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…
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Categories: Tax / IRS Penalties
Can You Request a Collection Due Process Hearing on FBAR Collections?
December 11th, 2024
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…
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Categories: FBAR
IRS Can Collect FBAR Penalties from Estate Distributees, Court Says
November 11th, 2024
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…
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Categories: FBAR
11th Circuit Rules Some (Not All) FBAR Penalties Unconstitutional
October 8th, 2024
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…
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Categories: FBAR
Ninth Circuit Upholds Reckless FBAR Penalties Against Tax Preparer
September 6th, 2024
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…
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Categories: FBAR
