» Tax / IRS Penalties
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 an Employee’s Illness be a Reasonable Cause for a Delayed Business Tax Filing?
July 9th, 2024
Small businesses, and even large ones, depend on their top employees to do everything from interfacing with customers to filing company tax returns. When a key employee has a serious physical or mental illness at tax time, it can create problems for…
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Categories: Tax / IRS Penalties
D.C. Circuit Court Restores IRS’s Foreign Business Assessment Authority
June 6th, 2024
U.S. taxpayers with foreign business interests must disclose those interests to the IRS or face substantial penalties. But for the past year, the IRS’s foreign business assessment authority has been off-line. A 2023 Tax Court decision held that the…
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Categories: Tax / IRS Penalties
IRS Denied Trust Fund Recovery Penalties Against “Errand Boy” Employee
May 3rd, 2024
Imagine working as an employee for a company for two years and then having the IRS impose trust fund recovery penalties worth more than 10 times your annual salary. That’s exactly what happened in Powell v IRS, but when it came time for trial, the…
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Categories: Tax / IRS Penalties
What Counts as Evidence in an Innocent Spouse Lawsuit?
April 9th, 2024
Can the IRS present new evidence in support of its administrative innocent spouse determinations? A recent Tax Court decision on a motion to strike provides new insight on what counts as evidence in an innocent spouse lawsuit. While the party present…
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Categories: Tax / IRS Penalties
IRS Must Repay Innocent Spouse Widow for Tax Lien, Court Says
November 9th, 2023
Everyone makes mistakes, and that includes the IRS. When the IRS collected an overpayment of unpaid taxes from a widow who qualified as an innocent spouse, the United States Tax Court told the government to give the money back. IRS Assesses Tax Lien…
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Categories: Tax / IRS Penalties
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
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
