tax Advice Archive
AICPA testifies to Congress on IRS service problems
February 17, 2022
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TweetShareSharePin0 Shares There’s still time to salvage this year’s tax filing season, or at least make a difference, if the IRS adopts recommended taxpayer relief measures, Jan F. Lewis, CPA, the chair of the AICPA’s Tax Executive Committee, told the U.S. Senate Committee on Finance in a hearing Thursday. Lewis, who is also a tax
Tax pros are subject of ‘spearphishing’ attacks
February 17, 2022
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News PRACTICE & PROCEDURES By Paul Bonner Identity thieves are targeting tax professionals with “spearphishing” emails masquerading as coming from the IRS or tax return preparation software providers, the Service advised in a news release Wednesday. A recent such ploy features the IRS logo, with a subject line such as “Action Required:
District Court in Rewwer Holds Improperly-Signed Timely Forms 843 Can be Informal Refund Claims
February 17, 2022
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TweetShareSharePin0 Shares The recent decision in Rewwer v. United States, 1:20cv495 (S.D. Ohio 2022) regarding a misfiled refund claim later corrected reaches the opposite conclusion from the Court of Federal Claims’ recent decision in Dixon v. United States, (Ct. Fed. Cl. 2022) (Dixon 2) (blogged here) and contradicts the decision in Fulham v. United States,
IRS offers further K-2/K-3 relief
February 16, 2022
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TweetShareSharePin0 Shares The IRS provided transition relief Wednesday under which eligible passthrough entities will not have to file new Schedules K-2 and K-3 for tax year 2021. The relief is outlined in News Release IR-2022-38 and frequently asked questions on the IRS website (“Schedules K2 and K3 Frequently Asked Questions” — see FAQ 15). Affected
11th Circuit Remands Willful FBAR Penalty Case Back to IRS Due to APA Violation
February 16, 2022
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TweetShareSharePin0 Shares Taxpayers who fail to disclose overseas accounts with more than $10,000 face hefty penalties under the Bank Secrecy Act. For willful violations the IRS can impose a penalty of up to the greater of $100,000 or 50% of the balance in each undisclosed account at the time of the violation (for a discussion
Revised voluntary disclosure form highlights cryptoassets
February 15, 2022
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TweetShareSharePin0 Shares An expanded reporting section and detailed instructions for reporting virtual currency are among the changes in a revised version of Form 14457, Voluntary Disclosure Practice Preclearance Request and Application, the IRS released Tuesday. Taxpayers file the form to make a preclearance request for the IRS to determine their eligibility to use the voluntary
Villanova Graduate Tax Program Looking To Hire A Professor of Practice/Faculty Director
February 15, 2022
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At the end of this academic year, my longtime colleague at Villanova Professor Joy Mullane will be returning to the faculty after a successful stint as Faculty Director of Villanova’s Graduate Tax Program. Villanova
Two Circuits Sustain Tax Court’s Inability to Grant Requested Relief
February 15, 2022
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TweetShareSharePin0 Shares Within the span of a few days the 2nd Circuit and the 4th Circuit each sustained a decision of the Tax Court that it lacked jurisdiction to grant the taxpayer the requested relief. The cases arise out of different sources of the Court’s jurisdiction and deal with different requests yet provide a common
The Train Tracks
February 14, 2022
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TweetShareSharePin0 Shares My three-year old grandson Sam is enamored with trains and train tracks. He loves to lay out the tracks and run Thomas and Thomas’ friends along the tracks. Unfortunately for Sam, his 14-month old sister has now learned to walk. She wants to do whatever Sam is doing, which includes playing with the
CFC in Dixon Holds Improperly-Signed Timely Forms 1040-X Cannot Be Informal Refund Claims
February 11, 2022
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TweetShareSharePin0 Shares We have reported before on a series of refund suits pending in cases brought by accountant John Castro on behalf of his clients. The most recent post is on the recent Fed. Cir. opinion in Brown (on which Keith blogged here). The Brown opinion actually came down before the opinion discussed in this
