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How large a penalty is too large, constitutionally speaking? Many people are shocked to learn that the maximum amount for a willful FBAR penalty is one half the balance of the account at the end of the reporting year. This can easily add up to millio… Read More

One day can make all the difference in tax lawsuits. But in Boechler PC v Commissioner of Internal Revenue, the Supreme Court of the United States said that filing a request for a collection due process appeal one day late may not have been enough to… Read More

What makes an error on a tax return or a missing form willful, rather than just negligent? Is signing a tax return enough to assume the taxpayer read and approved every line? A recent decision out of the United States District Court for the Southern… Read More

When the IRS makes a mistake, individuals and small businesses often want it corrected in a hurry. They may rush to file a lawsuit to correct the error. But if you miss certain steps before suing the IRS for a tax refund, your case could be dismissed… Read More

April 15 may be known as Tax Day, but every year, millions of taxpayers file tax extension forms to request more time to complete their tax returns. Many of those taxpayers don’t file the forms themselves. Instead, they rely on accountants to e-fil… Read More

When facing an IRS audit, it might seem expedient to take steps to protect your assets from collections. You might consider giving your home to your children, for example. But this only raises a new question of whether the IRS can enforce a judgment… Read More

What happens when a court decides the IRS miscalculated willful FBAR penalties? Will the penalty be forgiven? Is it the court’s job to fix the math errors, or should it remand the matter to the IRS to recalculate? And could that miscalculation actu… Read More

Whenever the IRS issues an assessment, it starts a clock. Unless taxpayers work quickly to address the issue, they will begin to accrue penalties and interest on that assessment. But what happens if you take the IRS to court over improper FBAR penalt… Read More