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Penalties Archive

Affordable Care Act Individual Mandate Penalties

TweetShareSharePin0 Shares Last month, the Supreme Court turned back a challenge to the Affordable Care Act (ACA), allowing to stand the Individual Mandate it created that penalizes taxpayers for not having proper health insurance and opening the way for President Biden and Congress to reimplement it. Internal Revenue Service (IRS) data from 2014 through 2018

Incarcerated Individual Subject to Delinquency Penalties Even Though Attorney Embezzled Funds and Failed To File His Tax Returns

TweetShareSharePin0 Shares We have often discussed the reach of the 1985 Supreme Court case United States v. Boyle. Section 6651(a)(1) and (2) impose delinquency penalties for failing to file a tax return or pay a tax unless the taxpayer can establish that the failure was due to reasonable cause and not willful neglect.  Boyle essentially stands for

If You Do Not File Timely, just how FBAR Penalties Have Evol…

TweetShareSharePin0 SharesWhen it comes to civil FBAR willfulness charges, intent is not needed. If the IRS analyzed FBAR charges versus you, it is vital to function to obtain those charges eliminated or decreased as rapidly as feasible. The United States federal government normally has 2 years to bring a legal action to apply the charge–

Imposing Penalties After Restitution Assessment

TweetShareSharePin0 Shares The recent case of Ervin v. Commissioner, T.C. Memo 2021-75 affirms the ability of the IRS to impose penalties after it makes a restitution assessment.  This case does not create precedent or cover new ground but does provide a reminder of how the restitution based assessments work.  We have previously written about restitution

Revisiting Supervisory Approval For Accuracy Penalties

TweetShareSharePin0 Shares Today’s post comes from University of Minnesota Law student, Patrick Riley Murray. Mr. Murray is not actually one of my students in my Federal Tax Procedure or the Federal Tax Clinic courses. However, Mr. Murray was referred to me by a student and previous Procedurally Taxing contributor Casey Epstein (see post here), as

Are FBAR Penalties Taxes for Purposes of the Flora Rule?

TweetShareSharePin0 SharesIn Norman, the Federal Circuit held that a currently obsolete Treasury Regulation did not cap FBAR fines for unyielding offenses at $100,000. Regulation 7(b)( 1) Mot. Mr. Mendu keeps in mind that, due to the fact that this Court does not have independent territory over the Defendant’s counterclaim for $752,920, this Court has to

How FBAR Penalties Have Evolved if You Do Not File Timely

TweetShareSharePin0 Shares FBAR Penalties FBAR Penalties FBAR Penalties: In recent years, the Internal Revenue Service has significantly increased the assessment and enforcement of FBAR Penalties for undisclosed foreign bank and financial accounts. When it comes to enforcement, the IRS has procedural safeguards on their side that limit a taxpayer’s ability to fight the penalty. That
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