» 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
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
Innocent Spouse Relief: Do You Qualify?
August 3rd, 2022
It’s one thing to owe back taxes and penalties because of your own mistakes. But when your spouse filed on your behalf, sometimes their errors or omissions can come as a shock. When your current or former spouse’s conduct leaves you on the hook f…
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First Circuit Court Says 8th Amendment Excessive Fines Clause Doesn’t Apply to FBAR Penalties
June 14th, 2022
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…
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What Happens if Your Accountant Fails to e-File Your Tax Extension Request?
March 7th, 2022
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…
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Categories: Tax / IRS Penalties
Miscalculated Willful FBAR Penalties Create Problems for the Court
February 2nd, 2022
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…
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Will an FBAR Lawsuit Stop IRS Interest Penalties?
January 25th, 2022
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…
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