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Could Your Estate Have to Pay Your FBAR Penalties?
October 9th, 2023
When the IRS issues FBAR penalties against elderly taxpayers, they may have an instinct to ignore the issue and hope it goes away after their death. However, a recent United States District Court case, United States v Gaynor, says your estate could h…
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Categories: FBAR
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Tax Deficiency Petition Deadline Isn’t Absolute, Appeals Court Says
September 8th, 2023
It is an unfortunate truth that many U.S. taxpayers wait until the last minute to deal with the IRS. This may mean filing extensions on their tax returns, or delaying contacting a tax attorney to respond to a deficiency notice. But is there ever a go…
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Categories: IRS Debt Collection
IRS Lacks Authority to Assess Penalties for Failure to Report Foreign Business Ownership, Tax Court Says
August 4th, 2023
U.S. taxpayers must disclose their ownership interests in foreign corporations to the IRS in yearly reports. The failure to report foreign business ownership can result in steep penalties. But a recent United States Tax Court case says that the IRS…
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Categories: Tax / IRS Penalties
Willful Blindness Leads to Willful FBAR Penalties After Doctor Hides Assets
July 6th, 2023
Taxpayers can’t turn a blind eye to their IRS filing requirements and expect to avoid willful FBAR penalties. A recent decision from the United States District Court for the Eastern District of Michigan shows that when an anesthesiologist tried to…
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Categories: FBAR
U.S. Supreme Court Excuses Secret IRS Summons, Sometimes
June 7th, 2023
Do you have the right to notice when the IRS demands production of your financial information? If the IRS reaches too far, do you have the right to take the government to court and limit that reach? The recent unanimous United States Supreme Court de…
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Categories: IRS Debt Collection
When Are Rental Real Estate Losses Not Deductible?
May 8th, 2023
Many U.S. taxpayers find themselves as landlords even while working full time in another industry. When the cost of owning a rental property starts to add up, you may wonder whether those costs can help offset your income on your U.S. tax returns. A…
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Categories: Tax Deductions
Does an IRS Passport Revocation Violate Taxpayers’ Right to Travel?
April 10th, 2023
When a taxpayer falls seriously behind in paying tax obligations, they may fall subject to IRS passport revocation procedures used to collect the outstanding tax liabilities. But does the IRS blocking a taxpayer’s ability to get or renew a passport…
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Categories: Tax / IRS Penalties
Will Reasonable Reliance on Tax Professionals Save You in an Audit?
March 9th, 2023
When taxpayers hire accountants to help prepare their tax returns, they expect it to be done right, and to save them from audits. But sometimes the quality of that product is limited by the information the taxpayers themselves provide. A recent Unite…
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US Sanctions Create FBAR Problems for Irani Immigrants
February 20th, 2023
International sanctions made it hard for two Irani immigrants to transfer proceeds from the sale of their home. But the U.S. District Court in Oregon said that what they did next created FBAR problems resulting in willful FBAR penalties that no jury…
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Categories: FBAR
What Happens if Your Tax Deficiency Petition is Filed Late?
January 5th, 2023
Anything can cause you to miss a deadline, from illness to mailing issues. But the IRS doesn’t tend to excuse those delays. This can raise the question, what happens if your tax deficiency petition is filed late? Can you ask for an extension? Can t…
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Categories: Tax / IRS Penalties
