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Plaintiff Tries to Dismiss His Own FBAR Lawsuit and Fails
May 10th, 2021
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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Inherited Secret Emergency Account Caused Willful FBAR Violations, Appeals Court Says
April 22nd, 2021
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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One Form, One Non-Willful FBAR Penalty, Circuit Court Says
April 8th, 2021
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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Can the IRS Impose FBAR Penalties if You Don’t Owe Taxes?
March 22nd, 2021
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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Do You Have to Pay Taxes on Out-of-Court Settlements?
March 8th, 2021
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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Categories: Tax Exemptions
Tags: For Referring Attorneys
High-Income Taxpayers: Get Your Taxes Filed On Time, or Else, IRS Says
February 23rd, 2021
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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Categories: IRS Debt Collection
IRS Tax Installment Agreements: What You Need to Know
February 8th, 2021
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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Categories: IRS Debt Collection
IRS Says Due Process Only Requires Written Response, Not a Hearing
January 22nd, 2021
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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Court Finds Drug CEO’s FBAR Violations Willful, Even if Unintentional
January 8th, 2021
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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IRS Ignores Reasonable Cause Statements in Assessing Foreign Trust Account Reporting Penalties, Website Says
December 29th, 2020
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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