tax Advice Archive

APA and FBAR Skirmishes Continue in Schwarzbaum v US

TweetShareSharePin0 Shares A couple of months ago in 11th Circuit Remands Willful FBAR Penalty Case Back to IRS Due to APA Violation I blogged about Schwarzbaum v United States, where the Eleventh Circuit held that Schwarzbaum willfully violated his FBAR reporting obligations for three years but that the IRS miscalculated the FBAR penalties. As I discussed,

Acute IRS challenges had chronic origins, GAO reports

TweetShareSharePin0 Shares The 2021 tax filing season featured IRS administrative challenges that were unprecedented in scope but long-standing in their causes, the U.S. Government Accountability Office (GAO) said in a report released Monday. And while the issues uncovered in the GAO’s study mostly stemmed from the COVID-19 pandemic’s continuing effects, they are likely to persist

Principal Residences as Collection Target: TIGTA Criticizes IRS Practice

TweetShareSharePin0 Shares In  The IRS Primarily Uses Lien Foreclosures When Pursuing Principal Residences, Which Do Not Provide the Same Legal Protections as the Seizure Process TIGTA released a report detailing how IRS uses judicial lien foreclosure suits rather than administrative collection tools when it targets a taxpayer’s principal residence to satisfy an assessed liability. The

IRS commissioner to senators: ‘Our efforts are working’

TweetShareSharePin0 Shares IRS Commissioner Charles Rettig updated members of the Senate Finance Committee Thursday on the Service’s performance in the soon-to-be-concluded tax filing season, as well as longer-term assessments of its efforts to modernize its operations, fill staffing gaps, and improve taxpayer service and enforcement. Asked repeatedly by senators about the IRS’s much-publicized backlog of

IRS eases application process for US residency certification

TweetShareSharePin0 Shares The IRS temporarily revised its procedures effective Monday for some submitters of Form 8802, Application for United States Residency Certification, to facilitate applications where the Service has not yet completed its processing of the applicant’s most recently filed tax return. The new policy, announced on the IRS’s website, applies to applicants whom the

Partial Pay Installment Agreements In the Dark

TweetShareSharePin0 Shares A recent TIGTA report highlights the redheaded stepchild of collection alternatives, partial pay installment agreements (PPIAs). The report highlights how relatively infrequently taxpayers enter into PPIAs and reveals how a lack of outward facing information about PPIAs contributes to their low use and jeopardizes taxpayer rights.  The TIGTA report’s use of a taxpayer
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