tax Advice Archive
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
IRS identifies paused taxpayer notices
February 10, 2022
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TweetShareSharePin0 Shares The IRS announced Wednesday in a news release the letters and notices it will not send taxpayers as it works through its backlog of unprocessed prior-year returns. In a Jan. 27 announcement, the Service said it was suspending certain automated letters and notices without identifying them specifically, saying only that they included, for
Causing Less Work for Themselves and Others
February 10, 2022
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Yesterday, the IRS announced that it was suspending a number of notices while it continues to work through its backlog of cases. Included in the suspended notices are the first three notices in the
Two Recent Circuit Level Decisions Appear to Dispute View That the Refund Claim Filing Requirement is Jurisdictional (Part 2)
February 10, 2022
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TweetShareSharePin0 Shares This is part two of a two-part post on jurisdiction issues arising from the filing of a claim for refund and the subsequent litigation. The prior post focused on the case of Morton v. United States and this post will focus on Brown v. United States. Carl Smith contributed to the commentary in
Tax pros share IRS service challenge stories, solutions
February 9, 2022
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TweetShareSharePin0 Shares Representatives of organizations of tax professionals and firms related their experiences in dealing with the IRS in an online forum Tuesday. Thousands of tax professionals and others logged in, filling long columns of chat and question sidebars with their own experiences and thoughts. The hourlong session, titled “Is Help on the Way From
