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IRS Denied Trust Fund Recovery Penalties Against “Errand Boy” Employee

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… Read More
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Categories: Tax / IRS Penalties
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What Counts as Evidence in an Innocent Spouse Lawsuit?

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… Read More
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Categories: Tax / IRS Penalties
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IRS Must Repay Innocent Spouse Widow for Tax Lien, Court Says

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… Read More
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Categories: Tax / IRS Penalties
US Tax Court

IRS Lacks Authority to Assess Penalties for Failure to Report Foreign Business Ownership, Tax Court Says

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… Read More
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Categories: Tax / IRS Penalties
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Does an IRS Passport Revocation Violate Taxpayers’ Right to Travel?

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… Read More
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Categories: Tax / IRS Penalties
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What Happens if Your Tax Deficiency Petition is Filed Late?

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… Read More
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Categories: Tax / IRS Penalties
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Innocent Spouse Relief: Do You Qualify?

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… Read More
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Courtroom, Gavel And Law Books

First Circuit Court Says 8th Amendment Excessive Fines Clause Doesn’t Apply to FBAR Penalties

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
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What Happens if Your Accountant Fails to e-File Your Tax Extension Request?

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
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Categories: Tax / IRS Penalties
IRS building

Miscalculated Willful FBAR Penalties Create Problems for the Court

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
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